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In re E.A.
Appellant Michael A. appeals the order terminating parental rights over his daughter, E.A. (E.), under Welfare and Institutions Code section 366.26.[1] Appellant contends that due process required a finding supported by clear and convincing evidence that he was an unfit parent or that return of the girl to his custody would create a risk of harm or detriment to the girl, and that the absence of such a finding or substantial evidence to support it precluded the court from terminating his parental rights. We agree and reverse.

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