Cited by

See generally Melissa W. v. Dep’t of Child Safety

9, 2024) (citing Melissa W. v. Dep’t of Child Safety, ¶¶ 7–8 (App. 2015)).

See Melissa W. v. Dep’t of Child Safety, –18, ¶ 9 (App. 2015).

See Melissa W. v. Dep’t of Child Safety, ¶ 6 (App. 2015) (observing that “drawing a negative inference” from a parent’s failure to testify at a termination trial is “particularly appropriate”).

See Melissa W. v. Dep’t of Child Safety, ¶¶ 5–8 (App. 2015) (holding that court may draw negative inference based on parent’s failure to testify).

The superior court, however, did not err in drawing such a negative inference, for “[a] central issue at [a severance hearing] is whether severance of parental rights is in the child’s best interests.” Melissa W. v. Dep’t of Child Safety, ¶ 6 (App. 2015) (citing A.R.S.

Melissa W. v. Dep’t of Child Safety, ¶ 5 (App. 2015); (an adverse inference is appropriate “under limited circumstances” when a party fails to call a witness).

Melissa W. v. Dep’t of Child Safety, –18, ¶ 9 (App. 2015).

Melissa W. v. Dep’t of Child Safety, ¶ 6 (App. 2015) (adding that there is “little benefit in adopting an approach that would permit a parent to forgo, without consequence, testifying about his or her ability to parent or about other circumstances relevant to the court’s determination”).

See Melissa W. v. Dep’t of Child Safety, -18, ¶ 9 (App. 2015) (finding arguments waived because mother did not support the arguments “with citation to relevant authority”).

In its closing, DCS argued that the court should draw a negative inference from the parents’ failure to testify, relying on Melissa W. v. Dep’t of Child Safety

See Melissa W. v. Dep’t of Child Safety, -18, ¶ 9 (App. 2015) (finding a party may waive an argument on appeal by failing to cite relevant legal authority as required by ARCAP 13(a)(7)).

See Melissa W. v. Dep’t of Child Safety, -18, ¶ 9, -53 (App. 2015).

See Melissa W. v. Dep’t of Child Safety, n.1, ¶ 2 (App. 2015) (citing 2014 Ariz. Sess.

See ARCAP 13(a)(7)(A) (providing that appellant’s argument must contain “contentions concerning each issue presented for review, with supporting reasons for each contention, and with citations of legal authorities, and appropriate references to the portions of the record on which the appellant relies”); Melissa W. v. Dep’t of Child Safety, -18, ¶ 9, -53 (App. 2015) (declining to address an appellant’s arguments that were not supported with citation to relevant authority).

P. 13(a)(7); Melissa W. v. Dep’t of Child Safety, -53 (2015) (failure to develop argument or cite to relevant authority waives argument on appeal).

See Melissa W. v. Dep’t of Child Safety, -18, ¶ 9, -53 (App. 2015).