constitute special factors that, when combined with the presumption in favor of M.C., satlsfy Trozel's due process requirements. 129 In addition, all of the statutory factors must be proved by clear and 'convine-ing evidence. "Due process requires that the state support its allegations by at least clear and convincing evidence" before a state miay "sever" a parent from his child. Santosky, 455 U.S. at 747-48, 102 S.Ct. 1388; see also People ex rel. A.J.L., 243 P.3d 244, 250 (Colo.2010) (stating that the termination of parental rights is a decision of "paramount gravity"). Consistent with the Supreme Court's direction, we adopted the clear-and convine ing standard "in proceedings involving termination of a parent-child, relationship." People ex rel. A.M.D., 648 P.2d 625, 631 (Colo.1982) (<HOLDING>). In AM.D., this court interpreted Colorado's
holding that the clear and convincing standard must apply in terminating the parentchild relationship after the children have been adjudicated dependent or neglected holding that where parents have previously stipulated that the children should be adjudicated as being in need of aid ocs still has the burden of proving in the subsequent termination of parental rights proceeding by clear and convincing evidence that the children were in need of aid holding that consortium is not a part of the parentchild relationship holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied holding that a bad faith claim must be met through the clear and convincing evidence standard