power. Parental Rights of J.L.N., 118 Nev. at 625, 55 P.3d at 958; Matter of Parental Rights as to N.J., 116 Nev. 790, 795, 8 P.3d 126, 129 (2000). Termination of parental rights implicates fundamental liberty interests of a parent’s relationship with his or her child. Parental Rights of D.R.H., 120 Nev. at 426-27, 92 P.3d at 1233. The procedures for terminating parental rights, and granting custody of a child to a nonparent, must be fundamentally fair. Id.; Santosky v. Kramer, 455 U.S. 745 (1982). Even when the fairness of the procedures afforded to the parents is not called into question, substantive due process nevertheless demands that the government have a basis for subjecting the parents to the procedures in the first instance. Licari v. Ferruzzi, 22 F.3d 344, 347 (1st Cir. 1994) (<HOLDING>). The United States Supreme Court has held that
holding that there is no due process violation where the ijs finding was not arbitrary and the alien was not denied a full and fair opportunity to present his claims recognizing  1983 substantive due process claim holding a police chase of a fleeing suspect that resulted in a fatal accident may support a substantive due process claim based on the theory that the officers conduct constituted arbitrary government action shocking the judicial conscience holding that mere neglect for prisoners safety does not amount to a substantive due process violation implying that intent to do harm would be an abuse of government power and amount to a substantive due process violation recognizing that substantive due process tenet which ensures that government action is not arbitrary regardless of whether the procedures afforded were fair