IMPLIED CONSENT BY FAILURE TO APPEAR-mother’s failure to appear at trial to terminate her parental rights was not due to “forces or circumstances beyond [her] control”; therefore, default by consent was proper.

C.R. v. Department of Children and Families, 225 So.3d 393 (2017)

Mother appealed the termination of her parental rights based on her failure to appear at
trial, arguing that the trial court abused its discretion in entering a default consent
(a/k/a/ implied consent by failure to appear) because she was unable to attend the trial
due to circumstances beyond her control. The Fifth DCA disagreed, stated that mother
chose to be absent, and distinguished the facts before it from those in E.A. v. Dep’t of
Child. & Fams., 894 So.2d 1049, 1052 (Fla. 5th DCA 2005), which was relied upon by

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