Termination of parental rights is available only by statute. Missouri provides for voluntary termination of parental rights only if the parent whose rights are to be terminated has consented in writing to the termination and if the termination will be in the best interests of the child.' All Missouri statutory provisions concerning termination of parental rights are to be "construed so as to promote the best interests and welfare of the child." The factors to be considered in determining the "best interest of the child" are enumerated in the statute, but they are quite general. This Note focuses on the Western District of the Missouri Court of Appeals' recent decision in In re R.A.S.

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