Cited by

–298, ¶¶ 21–27 (App. 2013).

When a parent faces circumstances that prevent them from “exercising traditional methods of bonding with his child [the parent] must act persistently to establish the relationship however possible and must vigorously assert [their] legal rights to the extent necessary.” ¶ 20 (App. 2013).

Decision of the Court ¶18 In an attempt to rebut the court’s finding of abandonment, ¶ 1 (App. 2013), Father argues “Mother actively hindered [his] and Paternal Grandmother’s ability to have contact with K.C.

(Citing Calvin B., ¶ 25 (App. 2013) and In re Maricopa Cnty.

But “a parent who has persistently and substantially restricted the other parent’s interaction with their child may not prove abandonment based on evidence that the other has had only limited involvement with the child.” –94 ¶ 1 (App. 2013).

Father relies on two cases: ¶ 21 (App. 2013); ¶ 15 (App. 2023).

¶12 to argue Mother obstructed his efforts to be present in C.C.’s life.

-94 ¶ 1 (App. 2013), while Mother contended she did not.

The non-petitioning parent may rebut that presumption by showing just cause, including that the other parent “persistently and substantially restricted [her] interaction with their child.” ¶ 1 (App. 2013).

Decision of the Court ¶9 Mother argues that she “was unable to have contact with the Children due to the multiple court orders and Father’s intentional violation of the Court order for phone calls.” Mother further contends she cannot have abandoned her children when Father restricted her access to them.

When asked by counsel why he didn’t “make more of an effort to see [his] daughter” during the two years before his accident, Father replied, “I—don’t have [a] response for that one.” ¶22 Father argues that Mother interfered with his relationship with A.M., thereby precluding a finding of abandonment.

A parent may rebut that presumption by showing just cause, including that the other parent “persistently and substantially restricted [her] interaction with [her] child.” ¶ 1 (App. 2013).

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

¶18 and argues that Father ignored her efforts to contact J.H.

Father argues that the court should have considered Mother's actions in undermining his relationship with Child.

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

view the evidence in the light most favorable to sustaining the superior court’s ruling.” ¶ 17 (App. 2013).

DISCUSSION ¶11 Father argues that the court erred (1) in relying on Mother’s subjective intent in finding that she did not abandon the child, and (2) in failing to determine whether termination was in the child’s best interests.

Neither argument explains how Father or Aunt restricted Mother from interacting with Amy, ¶ 22 (App. 2013) (father continuously and actively sought more involvement with son than mother would allow), and therefore do not justify her abandonment or explain her minimal efforts to maintain a relationship with Amy.