Justice W. WILLIAM LEAPHART delivered the Opinion of the Court.
¶ 1 In two separate hearings, the Eighteenth Judicial District Court, Gallatin County, terminated the parental rights of L.W. and M.S. with regard to their daughter, P.S. On different grounds, both parents appeal. We restate the issues as follows:
¶ 2 1. Did the District Court err by involuntarily terminating M.S.'s parental rights,
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