In Interest of B.T.B., 2018 UT App 157 (Aug. 23, 2018)

This appeal arose of a termination of a father’s parental rights.  Disavowing prior cases which had suggested that the conclusion that termination was in the best interest of the child “almost automatically” followed if one of the statutory grounds for termination had been met, the court of appeals clarified that courts should analyze the best interests of child independent of the enumerated statutory grounds for termination and “ask whether it is absolutely essential to the child’s best interest that a parent’s rights be permanently severed.”