Alainna King v. Arkansas Department of Humand Services and Minor Child

2021 Ark. App. 126
CourtCourt of Appeals of Arkansas
DecidedMarch 17, 2021
StatusPublished
Cited by3 cases

This text of 2021 Ark. App. 126 (Alainna King v. Arkansas Department of Humand Services and Minor Child) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alainna King v. Arkansas Department of Humand Services and Minor Child, 2021 Ark. App. 126 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 126 Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and integrity of this document DIVISION II 2023.06.23 10:24:34 -05'00' No. CV-20-558 2023.001.20174 Opinion Delivered March 17, 2021 ALAINNA KING APPEAL FROM THE PULASKI APPELLANT COUNTY CIRCUIT COURT, TENTH DIVISION V. [NO. 60JV-19-317]

ARKANSAS DEPARTMENT OF HONORABLE JOYCE WILLIAMS HUMAND SERVICES AND MINOR WARREN, JUDGE CHILD

APPELLEES AFFIRMED

N. MARK KLAPPENBACH, Judge

Appellant Alainna King appeals the July 2020 termination of her parental rights to

her three-year-old daughter, RL. King contends that the circuit court clearly erred in

finding that it was in RL’s best interest to terminate her parental rights because placing RL

with a relative was a less restrictive alternative to termination. We disagree and affirm.

The appellate court reviews termination-of-parental-rights cases de novo but will

not reverse the circuit court’s ruling unless its findings are clearly erroneous. Best v. Ark.

Dep’t of Human Servs., 2020 Ark. App. 485, 611 S.W.3d 690. A finding is clearly erroneous

when, although there is evidence to support it, the reviewing court on the entire evidence

is left with a definite and firm conviction that a mistake has been made. Id. In determining

whether a finding is clearly erroneous, an appellate court gives due deference to the

opportunity of the circuit court to judge the credibility of witnesses. Id. An order terminating parental rights must be based on a showing by clear and convincing evidence

(1) of one or more of the statutory grounds for termination listed in Arkansas Code

Annotated section 9-27-341(b)(3)(B) (Supp. 2019), and (2) that termination is in the best

interest of the juvenile. Id. The best-interest inquiry requires the circuit court to take into

consideration (1) the likelihood that the juvenile will be adopted if the termination petition

is granted; and (2) the potential harm, specifically addressing the effect on the health and

safety of the child, caused by returning the child to the custody of the parent. Id.

King does not challenge the existence of statutory grounds on which to terminate

her parental rights. 1 King does not challenge the circuit court’s findings regarding RL’s

adoptability and whether returning her to King’s custody would pose potential harm to RL.

Instead, King makes a limited “best interest” challenge, contending that that there was a less

restrictive alternative to termination that would preserve familial bonds. Specifically, King

asserts that the evidence weighed in favor of custody being granted to RL’s maternal

grandmother. We disagree that King has demonstrated clear error in the circuit court’s best-

interest finding.

Arkansas Code Annotated section 9-27-329(d) (Supp. 2019) provides that in initially

considering the disposition alternatives and at any subsequent hearing, the court shall give

preference to the least restrictive disposition consistent with the best interest and welfare of

the juvenile. A circuit court is permitted to set termination as a goal even when a relative

is available and requests custody. Best v. Ark. Dep’t of Human Servs., 2020 Ark. App. 485,

1 The circuit court found two statutory grounds had been proved against King: (1) the failure-to-remedy ground and (2) the aggravated-circumstances ground. See Ark. Code Ann. § 9-27-341(b)(3)(B).

2 611 S.W.3d 690; Dominguez v. Ark. Dep’t of Human Servs., 2020 Ark. App. 2, 592 S.W.3d

723. This is because the Juvenile Code lists permanency goals in order of preference,

prioritizing a plan for termination and adoption unless the juvenile is already being cared

for by a relative, the relative has made a long-term commitment to the child, and

termination of parental rights is not in the child’s best interest. Id. Each termination-of-

parental-rights case is decided on a case-by-case basis. Migues v. Arkansas Dep’t of Human

Servs., 2019 Ark. App. 439, 586 S.W.3d 221.

King does not dispute the findings that led to RL’s removal from her custody and

the reasons that she could not regain custody. RL, who was born in December 2016, is a

medically fragile child, has Axenfeld-Rieger syndrome, is severely autistic, and is severely

developmentally delayed; she has a seizure disorder, has a g-tube to meet her nutritional

needs, and requires intensive personal care. RL was removed from King’s custody in March

2019, when RL was two years old, and placed in the custody of the Arkansas Department

of Human Services (DHS). The child’s removal was prompted when King took RL to the

hospital because she was running fever, coughing, and lethargic. Medical personnel

observed that RL had extensive bruises, had head lice, and was significantly underweight.

King did not know when, where, or who caused the non-accidental bruises on RL. King

told hospital personnel that RL could tolerate substantial feeding by mouth, which was

inaccurate. RL was hospitalized for failure to thrive and child maltreatment. After RL was

taken into DHS custody, RL gained weight and recovered from her illness and bruising,

although she will continue to need extensive personal care and attention for the rest of her

life.

3 The goal of this case was reunification with the mother or obtaining RL a permanent

custodian. King was living in squalor when DHS intervened, and it became clear that King

could not or would not provide RL the extraordinary care that she requires. Over the next

sixteen months of this DHS case, King demonstrated difficulty adequately caring for herself,

much less a child, and King did not focus her available efforts on RL. King instead focused

her attention on her boyfriend, who exhibited behaviors that were unsafe for RL. Although

in the latter months King attempted to comply with the DHS case plan, King did not benefit

from the services to an extent that she would ever be able to safely parent RL. King had

only supervised visitation. In March 2020, the circuit court conducted a permanency-

planning hearing, at which the goal was changed to adoption, permitting DHS to file a

petition to terminate King’s parental rights. At that hearing, the circuit court found that she

was often resistant to learning better and safer methods to care for RL. King lacked insight

and understanding of RL’s complex and severe conditions or how to care for her.

The evidence at the termination hearing showed that RL could not be safely reunited

with her mother, who was not a fit parent by any standard. RL’s grandmother, Connie

Breeding, lived in Texas and had a home study approved in May 2020, just before the

termination proceedings commenced. Breeding had custody of RL’s older sister

(approximately age four), but Breeding did not have an established relationship with RL

and had not visited her. Breeding’s last visit with RL, which lasted a couple hours, was in

late 2018. At the termination hearing, Breeding testified that RL needs to be with King,

who loves RL very much. King’s biological father, Donald King, lived in Louisiana, and he

4 expressed hope that King could be reunited with RL at some point in the future, perhaps

three, four, or five years down the road.

RL was never placed in a relative’s custody and remained in foster care throughout

this case. RL’s foster parents expressed desire to adopt her, and the adoption specialist found

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2021 Ark. App. 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alainna-king-v-arkansas-department-of-humand-services-and-minor-child-arkctapp-2021.