Div. of Family & Youth Servs., 45 P.3d 1198, 1206 n. 22 (Alaska 2002) ("Mental illness, absent related conduct, cannot be a basis for termination of parental rights."). 21 . A finding that a child is in need of aid under AS 47.10.011(11) requires a showing that "the parent, guardian, or custodian has a mental illness, serious emotional disturbance, or mental deficiency of a nature and duration that places the child at substantial risk of physical harm or mental injury." 22 . 165 P.3d 605, 618-19 (Alaska 2007). 23 . Id. at 619. 24 . Compare CINA Rule 15(c) (requiring proof by a preponderance of the evidence in an adjudication) with CINA Rule 18(c) (requiring proof by clear and convincing evidence in a termination proceeding). 25 . See Rick P. v. State, OCS, 109 P.3d 950 (Alaska 2005) (<HOLDING>); D.M. v. State, Div. of Family & Youth Servs.,
holding that the clear and convincing standard must apply in terminating the parentchild relationship after the children have been adjudicated dependent or neglected recognizing that the department is required to present clear and convincing evidence to support termination of a parents parental rights holding that termination of benefits under the aid to families with dependent children program must be preceded by a hearing 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 a superior court properly considered the childrens need for permanency a crucial need for young children in evaluating the best interests of the child in a termination proceeding