§9.34 Severe or Recurrent Acts of Abuse

LibraryJuvenile Law Deskbook (2021 Supp.)

3. (§9.34) Severe or Recurrent Acts of Abuse

A “severe act” finding in the underlying adjudicatory proceeding under § 211.031.1, RSMo Supp. 2019, may serve as conclusive evidence of the severe act in the termination case. In In re J.A.F., 570 S.W.3d 77 (Mo. App. W.D. 2019), the court found that the father had no “grounds to dispute that he committed a severe act of emotional abuse” given that the underlying court—under a clear and convincing evidence standard involving the same set of facts and
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