V.M. v. Division of Child & Family Servs., 2020 UT App 35, 461 P.3d 326 (Mar. 5, 2020)
The appellant argued the juvenile court committed legal error by relying on transcripts from a separate criminal proceeding when substantiating a DCFS finding of sexual abuse. In addition to noting that the juvenile court relied on other evidence besides paper transcripts—including an audio recording, witness testimony, and video of the forensic interview—the court of appeals rejected the argument that black letter law prohibited fact-finders from considering transcripts in making credibility determinations in all circumstances.