In Re: R.I.S. & A.I.S.

Father "C.S." is the biological father of two minor children, R.I.S. and A.I.S. He was incarcerated in a state correctional facility with a minimum release date of June 2012. He appealed a superior court's reversal of a trial court order that ordered the involuntary termination of his parental rights and for changes in the placement goals for the children from reunification to adoption. Upon review of the facts presented at trial, the court reversed the superior court and took the opportunity to reiterate the principle that: "a parent’s incarceration, standing alone, cannot constitute proper grounds for the termination of his or her parental rights."