IN RE: THE PARENTAL RIGHTS AS TO A.D.R. AND J.D.R. (2023)

ORDER OF AFFIRMANCE

This is an appeal from a district court order terminating appellant's parental rights to two of her minor children. Eighth Judicial District Court, Family Court Division, Clark County; Frank P. Sullivan, Judge.¹

Appellant Jennifer K.W. asserts that this court must reverse the district court's decision to terminate her parental rights because the minor children did not have counsel for the entirety of the termination proceedings.² While Jennifer properly points out that NRS 128.100(2) requires a child to be represented by counsel during parental rights termination proceedings, she lacks standing to seek reversal on this ground. See Beazer Homes Holding Corp. v. Eighth Judicial Dist. Court, 128 Nev. 723, 731, 291 P.3d 128, 133 (2012) (providing that “a party generally has standing to assert only its own rights”). The children were parties to this action who had counsel at the beginning of the proceedings, at the end of the proceedings, and on appeal. As parties, the children could raise this argument on their own behalf. They have not done so. Thus, we conclude Jennifer lacks standing to raise this argument. See Logan v. Abe, 131 Nev. 260, 263, 350 P.3d 1139, 1141 (2015) (“Standing is a question of law reviewed de novo.”).

Additionally, to the extent Jennifer challenges the evidence and witness testimony considered by the district court, she admits she did not object below. She thus waived these arguments. See Old Aztec Mine, Inc. v. Brown, 97 Nev. 49, 52, 623 P.2d 981, 983 (1981) (“A point not urged in the trial court, unless it goes to the jurisdiction of that court, is deemed to have been waived and will not be considered on appeal.”). Further, Jennifer fails to present cogent arguments and legal authorities supporting her assertion that because this was a termination of parental rights proceeding, the district court had a duty to ensure compliance with witness disclosures, even if she did not object. Edwards v. Emperor's Garden Restaurant, 122 Nev. 317, 330 n. 38, 130 P.3d 1280, 1288 n.38 (2006) (explaining that this court need not consider arguments that are not cogently argued or supported by relevant authority). Lastly, the district court did not err in taking judicial notice of and considering the documents from Jennifer's previous protective custody actions. See NRS 47.150; Occhiuto v. Occhiuto, 97 Nev. 143, 145, 625 P.2d 568, 569 (1981) (explaining that judicial notice may be appropriate when there is a close relationship between the underlying case and the proceeding that is the subject of the judicial notice). Accordingly, we

ORDER the judgment of the district court AFFIRMED.

Stiglich, C.J.

Lee, J.

Bell, J.

FOOTNOTES

1.   Pursuant to NRAP 34(f)(1), we have determined that oral argument is not warranted in this appeal.

2.   Although Jennifer does not directly challenge the merits of the district court's order terminating her parental rights, we conclude that substantial evidence supports the district court's findings that respondent State of Nevada Department of Family Services demonstrated grounds of parental fault and that termination was in the children's best interest by clear and convincing evidence. In re Termination of Parental Rights as to N.J., 116 Nev. 790, 800-01, 8 P.3d 126, 132-33 (2000); NRS 128.105(1).