Cited by

Good cause “exists under a variety of circumstances.” -86 (Minn. 1997).

a party cannot raise a new issue on appeal, “[n]or may a party obtain review by raising the same general issue litigated below but under a different theory”); (refusing to consider important constitutional challenges to an involuntary termination of parental rights because the arguments were not raised in the district court); (citing this aspect of C.L.L.); (same).

Our scope of review on appeal is “limited to determining whether the [district court’s] findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

Our scope of review on appeal is “limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

(refusing to reverse termi nation of parental rights for harmless error) ; - 40 (Minn. App. 1995) ( refusing to reverse termination for harmless error ) (implicitly overruled on other grounds by ), rev .

- 86 (Minn. 1997); -36 (Minn. 2014).

(applying this aspect of Thiele in a juvenile-protection appeal).

Instead, “a voluntary termination order may be rescinded only upon a showing of fraud, duress, or undue influence.”

6 ( applying waiver rule in termination of parental rights case); In re Welfare of S.G.

), review denied (Minn. Mar.

On appeal from a district court’s termination of parental rights, appellate courts review whether the district court’s findings “address the statutory criteria [for the termination of parental rights ], whether those findings are supported by substantial evidence, and whether they are clearly erroneous.” d 481, 484 (Minn. 1997); see In re Welfare of Children of T.R.

A district court’s finding regarding whether a parent’s desire for a voluntary termination of parental right s is based on good cause “mus t be upheld if supported by substantial evidence and not clearly erroneous.”

In reviewing the district court’s findi ngs, “appellate courts are limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

We conclude that the district court did not err in its assessment of mother’s motion— that she “presented no explanation for her claim of coercion or threat such as to justify an evidentiary hearing.” –85 (Minn. 1997) (affirming TPR based on father’s voluntary consent when he claimed that county coerced him with promises that district court deemed illusory).

see also In re Welfare of Children of Coats , (applying waiver analysis to termination proceeding).

As to the purported legal redundancy, f ather argues that “[t]he existence of an involuntary basis for termination is irrelevant if the Court finds good cause for a voluntary termination,” relying on

Our review of a district court’s decision to terminate parental rights is “limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

Our review of a district court’s decision to terminate parental rights is “limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

(reviewing district court’s decision to allow parent to withdraw voluntary termination of parental rights for abuse of discretion), review denied (Minn. July 28, 2011).1 The parent bears the burden of showing a “serious

On appeal from a decision terminating 7 parental rights, “appellate courts are limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

(noting that, when an argument that a parent’s voluntary termination of parental rights was improper had not been raised in district court, the question was not properly before the supreme court and that “[t]he gravity of termination proceedings” was “not a sufficient reason to abandon our establ

Co., , 584 n. 2 (Minn.2010); Higher Educ.

(involuntary termination); (voluntary termination).

(stating that issues not raised in district court are waived on appeal); (invoking Minn. R. Civ.App.

ANALYSIS On appeal from a decision terminating parental rights, “appellate courts are limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.”

“Good cause” under the voluntary termination statute “exists under a variety of circumstances.” -86 (Minn.1997); -19 (Minn.1982) (upholding the trial court’s finding of good cause when a one-year-old child had resided in a foster home since birth; the parent had not visited the child; and the parent did not believe she was able to take care of a second child); In r

ANALYSIS On review of a district court’s findings in a termination-of-parental-rights case, this court is “limited to determining whether the findings address the statutory criteria, whether those findings are supported by substantial evidence, and whether they are clearly erroneous.” (citation omitted).