In re G.D., 2021 UT 19 (June 10, 2021)

In this case involving an appeal from a termination of parent rights based upon years of dysfunctionality, substance abuse, and criminal conduct, the appellant asserted error based upon the district court failing to apply a “beyond a reasonable doubt” standard of proof. The supreme court noted that “[a]lthough the U.S. Supreme Court has opened the door for states to adopt an evidentiary standard higher than ‘clear and convincing’ for termination proceedings,” the Utah court declined to adopt the heightened standard.