## Facts

- Six days after D.R.T.’s birth, the child’s mother (“Jet”) contacted a social worker stating she was having difficulty controlling her temper, feared she might harm the baby, and needed help.
- A police officer and a Department of Family Services (DFS) caseworker responded to Jet’s home and found her crying and distressed; Jet stated she screamed at the baby when the child cried and feared she might hurt the child.
- The officer took D.R.T. into protective custody, and DFS filed a juvenile neglect petition.
- At a combined initial appearance and shelter-care hearing, the juvenile court advised Jet of her rights, including the right to counsel (including appointed counsel if indigent), the right to contest the allegations, and that if the child was not reunified within roughly 15–22 months, the State could seek termination of parental rights.
- The juvenile court questioned Jet about her mental health; Jet reported diagnoses (including bipolar disorder) but said she was clear-headed, understood the proceedings, and was not then on medication.
- Jet repeatedly declined appointed counsel and admitted the neglect allegations.
- After later obtaining counsel, Jet moved to withdraw her admission, arguing her mental illness and incomplete understanding made the admission involuntary and that she was not sufficiently warned about potential termination under other statutory routes.
- A later psychiatric evaluation described Jet as bipolar with high-average intellectual functioning and did not indicate incapacity to make a voluntary admission.

## Issues

1. Whether due process required the juvenile court, at the neglect adjudication stage, to give more detailed advisements about possible future termination of parental rights under other statutory provisions.
2. Whether due process was violated by accepting Jet’s admission despite her mental illness, i.e., whether the admission was knowing, intelligent, and voluntary such that denial of withdrawal was an abuse of discretion.

## Decision

- The Wyoming Supreme Court affirmed the order denying Jet’s motion to withdraw her neglect admission.
- Due process did not require advisements detailing every statutory method by which parental rights might later be terminated; informing Jet of the possibility of termination if reunification did not occur was sufficient.
- The record supported that Jet’s admission was knowing and voluntary despite her diagnoses; the juvenile court did not abuse its discretion in refusing withdrawal.

## Legal Principles

- Juvenile neglect proceedings are civil but implicate a parent’s fundamental liberty interest in the care and custody of a child; due process requirements are context-dependent and flexible.
- At the neglect stage, due process is satisfied when the parent is advised of the right to counsel, the right to contest allegations, and the general possibility that failure to reunify may lead to termination of parental rights; the court need not provide exhaustive instruction on all future statutory termination pathways.
- Mental illness alone does not invalidate an admission; voluntariness turns on the contemporaneous record of comprehension, ability to proceed, and informed choice, including any waiver of counsel.
- A ruling on a motion to withdraw an admission in a neglect proceeding is reviewed for abuse of discretion, with deference to the juvenile court’s assessment of the parent’s understanding and demeanor at the hearing.

## Conclusion

The Wyoming Supreme Court held that the juvenile court’s advisements satisfied due process and that the mother’s in-court admission of neglect was voluntary and knowing notwithstanding her mental health diagnoses; therefore, the juvenile court acted within its discretion in denying withdrawal of the admission.


In re Interest of D.R.T., 241 P.3d 489 (Wyo. 2010)