## Facts

- Hennepin County filed a CHIPS petition concerning four children of R.D.L. (mother) and J.W. (father), alleging prostitution in the children’s presence, domestic violence witnessed by the children, and illegal drug use in the children’s presence.
- The juvenile court adjudicated the children in need of protection or services and placed them in foster care.
- The County later sought to terminate parental rights (TPR) to the four children for failure to comply with case plans addressing chemical dependency, mental health, parenting, housing, and separation from the father.
- After the County filed that TPR petition, R.D.L. gave birth to a fifth child.
- The County offered not to rely on a voluntary termination of rights to the four older children as a basis to seek termination as to the newborn; R.D.L. declined.
- Following trial, the juvenile court involuntarily terminated both parents’ rights to the four older children; the court of appeals affirmed.
- Two days after the affirmance, the County petitioned to terminate parental rights to the newborn, invoking Minn. Stat. § 260C.301, subd. 1(b)(4), which presumes palpable unfitness when parental rights to another child were previously involuntarily terminated.
- In the newborn’s TPR case, R.D.L. did not offer evidence to rebut the presumption; she challenged the presumption’s constitutionality, arguing unequal treatment compared to parents whose prior terminations were voluntary.
- The juvenile court terminated parental rights to the newborn and found termination was in the child’s best interests; the court of appeals affirmed.
- The Minnesota Supreme Court granted review on the equal-protection challenge.

## Issues

1. Whether Minn. Stat. § 260C.301, subd. 1(b)(4)’s rebuttable presumption of palpable unfitness, triggered by a prior involuntary TPR but not by a prior voluntary TPR, violates equal protection under the United States and Minnesota Constitutions.

## Decision

- The Minnesota Supreme Court affirmed the termination order.
- The court applied strict scrutiny because parental rights are fundamental.
- Assuming parents with prior voluntary and involuntary terminations are similarly situated, the court held the distinction survives strict scrutiny.
- The court held the State has a compelling interest in protecting children and achieving timely permanency.
- The court concluded the presumption is narrowly tailored because it is triggered only by a prior involuntary TPR with heightened procedural protections and judicial findings, is rebuttable, and does not eliminate the independent best-interests determination.
- Because R.D.L. presented no rebuttal evidence and the juvenile court found termination served the newborn’s best interests, the termination was upheld.
- Justice Page dissented.

## Legal Principles

- Parental rights are fundamental; classifications that burden parenting are subject to strict scrutiny under federal and state equal-protection guarantees.
- The State has a compelling interest in child protection and prompt permanency decisions in juvenile protection matters.
- A rebuttable presumption of palpable unfitness based on a prior involuntary TPR can be constitutionally permissible when the prior proceeding required robust procedural safeguards and judicial findings supporting termination.
- A statutory presumption is more likely to satisfy strict scrutiny when it remains rebuttable and the court must still determine that termination is in the specific child’s best interests.
- Differential treatment between prior involuntary and voluntary terminations may be justified where involuntary termination necessarily rests on findings and proof standards not required for voluntary relinquishment.

## Conclusion

The Minnesota Supreme Court upheld Minn. Stat. § 260C.301, subd. 1(b)(4) against an equal-protection challenge, holding that the rebuttable presumption of palpable unfitness triggered by a prior involuntary TPR is narrowly tailored to a compelling child-protection and permanency interest and does not eliminate individualized adjudication through rebuttal and best-interests findings.


In re Welfare of Child of R.D.L., 853 N.W.2d 127 (Minn. 2014)