The Colorado Supreme Court granted Petitions for Writ of Certiorari on issues of (a) whether a trial court is required to make a specific finding considering and eliminating less drastic alternatives before ordering termination of the parent-child legal relationship, and if so, whether the trial court must do so using the best interests of the child standard or the adequacy standard; and (b) whether the Court of Appeals acted discordantly with applicable decisions of the Court when it failed to properly apply the clearly erroneous standard of review, substituting the trial court’s factual findings with its own judgment, and reversed the trial court’s termination decree.

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