The recent Arizona Supreme Court Case of Trisha A. v. Department of Child Safety (2019) raised important issues regarding due process and parental rights in Arizona and federal constitutional law, mainly as they interact with an obscure but important part of Arizona’s child welfare statutes relating to parental termination, A.R.S. 8-537(C). In this thesis, I will reconstruct the developments that led to the Trisha case, discuss its possible implications, and briefly suggest possible recommendations for reform. This thesis will thus proceed 1: through the relevant federal caselaw that outlines the Supreme Court interpretation of the U.S. Constitution in the realm of family rights and due process; 2: through relevant Arizona statutes regarding the termination of parental rights; 3: the legislative history of A.R.S. 8-537(C) specifically; 4: through relevant Arizona state caselaw on parental terminations, 5: through the implications and costs of A.R.S. 8-537(C), before briefly concluding with possibilities for reform.