O.B. v. Department of Children & Family Services
O.B. v. Department of Children & Family Services
Opinion of the Court
We affirm the final judgment of involuntary termination of parental rights of the father in this case. We strike the portion of paragraph sixty-two of the judgment that “finds that the children are at substantial risk of prospective abuse, neglect or abandonment,” because it is misleading and unnecessary to support the final judgment.
We write primarily to comment that the structure of the final judgment in this case makes it difficult for both the attorneys and this court to review the judgment to determine its adequacy. The judgment has seventy enumerated paragraphs. Its structure does not appear to be based on. form 8.983 of the Florida Rules of Juvenile Procedure. Many trial courts, including some in the Sixth Judicial Circuit, have created an excellent standard form that is actually more helpful than the form in the rule book. That form separates the order into easily identifiable sections that include: (1) the date or dates of the adjudicatory hearing and the individuals who were present at the hearing, (2) the procedural history of the case, (3) a confirmation that the parent’s right to counsel has been fulfilled, (4) a delineation of each of the alleged statutory grounds for termination as to each parent, (5) findings of fact in an orderly structure, (6) a declaration that each alleged statutory ground has or has not been proven by clear and convincing evidence, (7) a finding on single parent grounds,
Affirmed.
. Such a finding is not necessarily applicable in all cases, but if applicable, the inclusion of a finding on single parent grounds might support the affirmance of a termination order as to one parent even though the order must be reversed as to the other parent. See In re L.C., 908 So.2d 568, 573 (Fla. 2d DCA 2005).
Case-law data current through December 31, 2025. Source: CourtListener bulk data.