P.E. failed to appear in court for a hearing scheduled to consider possible termination of her parental rights to her daughter. Her parental rights were terminated and she appealed to the Second District Court of Appeal. The 2nd DCA ruled that by law a parent's failure to appear at such a hearing, despite proper notification, constitutes a voluntary consent to the termination of rights. The 2nd DCA also noted that its ruling was in conflict with rulings from both the Third and Fifth District Courts of Appeal. In this case, however, the 2nd DCA reversed the termination order for another reason.