In the Matter of the Custody and Parental Rights of M.M.
271 Mont. 52, 894 P. 2d 298 (1995)

The court approves termination of the father's parental rights with regard to M.M., who had been diagnosed with FAS. The decision rested largely on the failure of the father to comply with the terms of a treatment plan.

One element of the treatment plan was that the father "take classes on fetal alcohol syndrome." 894 P. 2d at 299. The treatment plan was prepared by the Lewis and Clark County Department of Family Protective Services.