Case Plan Goals-Due process requires notice of proposed change to permanency goal and strict adherence to statutory requirements.

In Interest of T.C., — So.3d —- (2018)

Mother sought certiorari review of the trial court’s order that placed two of her children in a permanent guardianship with their paternal grandparents and gave the father permanent custody of a third child. Mother argued that the trial court departed from the essential requirements of the law because the Department filed a case plan with the changed permanency goals less than twenty-four hours prior to the judicial review hearing, and the mother was not informed prior to the judicial review that the Department and the Guardian ad Litem Program were seeking to change the permanency goals, nor that an evidentiary hearing would be conducted at the judicial review.

The Second DCA granted the petition and quashed the order, finding that the failure to notify mother of the proposed goal changes was contrary to statutory requirements, and denied the mother of procedural due process to present witnesses and cross-examine.

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