against self-incrimination, which violates the Fifth Amendment, and an order compelling a parent’s participation in counseling or reunification services, the success of which might hinge on the admission of abuse. See, e.g., In re A.W., 231 Ill.2d 92, 324 Ill.Dec. 530, 896 N.E.2d 316, 326 (2008) (“[A] trial court may order a service plan that requires a parent to engage in effective counseling or therapy, but may not compel counseling or therapy requiring the parent to admit to committing a crime.”); In the Interest of C.H., 652 N.W.2d 144, 150 (Iowa 2002) (“The State may require parents to otherwise undergo treatment, but it may not specifically require an admission of guilt as part of the treatment.”); Minh T. v. Ariz. Dep’t of Econ. Sec., 202 Ariz. 76, 41 P.3d 614, 618 (App. 2001) (<HOLDING>); State v. Suzette M. (In re Clifford M.), 6
recognizing distinction between smith and mcdonnell recognizing distinction between tolling and estoppel recognizing a distinction between a treatment order that requires parents to admit criminal misconduct and one that merely orders participation in family reunification services recognizing this distinction recognizing distinction between two types of waiver