Christine Rodriguez v. Arkansas Department of Human Services and Minor Children

2024 Ark. App. 469
CourtCourt of Appeals of Arkansas
DecidedOctober 2, 2024
StatusPublished
Cited by1 cases

This text of 2024 Ark. App. 469 (Christine Rodriguez v. Arkansas Department of Human Services and Minor Children) 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
Christine Rodriguez v. Arkansas Department of Human Services and Minor Children, 2024 Ark. App. 469 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 469 ARKANSAS COURT OF APPEALS DIVISION I No. CV-24-111

CHRISTINE RODRIGUEZ Opinion Delivered October 2, 2024

APPELLANT APPEAL FROM THE GARLAND COUNTY CIRCUIT COURT V. [NO. 26JV-23-196]

ARKANSAS DEPARTMENT OF HONORABLE LYNN WILLIAMS, HUMAN SERVICES AND MINOR JUDGE CHILDREN APPELLEES AFFIRMED

CINDY GRACE THYER, Judge

Christine Rodriguez appeals from the order of the Garland County Circuit Court

placing custody of her two children, MC1 and MC2, 1 with their father and closing their

dependency-neglect case. On appeal, she argues that the circuit court abused its discretion

when it denied her motion for continuance; in addition, she contends that the court erred

in granting custody to the children’s father and closing the case without giving her proper

notice that reunification services would be terminated. We affirm.

I. Factual and Procedural Background

The Arkansas Department of Human Services (DHS) received a phone call from local

law enforcement on April 27, 2023, after MC1 flagged down a passing motorist to request

1 MC1 is a female born in 2008, and MC2 is a male born in 2011. help because there was no food in the home. Upon conducting a child-welfare check at the

home of a family friend where MC1 had been staying, DHS determined that Rodriguez’s

whereabouts were unknown. DHS also learned that fifteen-year-old MC1 had not attended

school since January. Accordingly, DHS exercised a seventy-two-hour hold on MC1 and

subsequently filed a petition for dependency-neglect alleging that she was at substantial risk

of serious harm as a result of abandonment, abuse, neglect, and parental unfitness. Although

DHS noted that it had not been able to locate MC2 at the time it filed the petition, it asked

that he also be placed in DHS’s custody.

The circuit court entered an ex parte order for emergency custody on May 1, placing

MC1 in DHS’s custody. The court also directed DHS to locate MC2, assess his home for

safety, and, if necessary, take him into custody as well. Following a probable-cause hearing,

which Rodriguez did not attend, the court continued custody of MC1 with DHS and ordered

MC2 into DHS custody. The adjudication hearing was scheduled for June 21.

On June 21, Rodriguez appeared for the hearing, as did the children’s father, Dennis

Lorenzo, who lives in Arizona. At the parents’ request, the court appointed counsel for both

of them. In addition, the court placed custody of MC2 with Lorenzo and ordered that MC1

should have weekly phone calls with him until the next hearing. The court then continued

the remainder of the adjudication hearing until July 19.

Following the July 19 hearing, the court entered an agreed adjudication order. In this

order, the parents stipulated that the children were dependent-neglected due to

environmental neglect resulting from Rodriguez’s failure to provide adequate supervision.

2 The court also determined that Lorenzo was a nonoffending parent. With no objection

noted by Rodriguez, the court placed the children in Lorenzo’s temporary custody and set

the goal of the case as reunification with a fit and proper parent and a concurrent goal of

placement with relatives or fictive kin. Finally, the court scheduled a review hearing for

October 25.

On October 23, however, the court entered an order continuing the review hearing

until November 15. At the outset of the November hearing, Rodriguez’s counsel informed

the court that she was not present. Counsel stated that Rodriguez had told him she did not

receive notice of the hearing and that he realized after going through his communication

with her that he had failed to tell her about it. Counsel therefore asked for a one-week

continuance “so [Rodriguez] could have notice of the hearing.” DHS objected to the

continuance, noting that Lorenzo was ready to proceed with the hearing that day. The court

denied the request and proceeded with the review hearing.

During the hearing, Jamie Moran, the case supervisor, testified that the initial removal

of MC1 occurred because she had called for help because she had nothing to eat and was

unable to attend school. MC1 had been staying with Rodriguez’s elderly friend; the friend

was unable to care for MC1, and Rodriguez could not be located. Since that time, both

children had been placed with their father, whom Moran described as the nonoffending

parent. She added that DHS had asked Arizona Child Protective Services to conduct an

assessment of his home, and that agency determined that he was fit and appropriate. She

further stated that the children had been placed with him, and they were happy and doing

3 well. Because DHS had had no contact from Rodriguez, it was Moran’s recommendation

that the case be closed and custody of the children placed with their father.

Rodriguez’s attorney called no witnesses and presented no evidence, but he did voice

Rodriguez’s objection to closure of the case and asked “for the full time that this case be

worked on.” The court nevertheless granted the motion to close and awarded permanent

custody of the children to Lorenzo. An order to that effect was entered on November 21.

On November 22, Rodriguez moved to set aside the order placing the children with

their father and closing the case. Rodriguez argued that the closure of the case amounted to

a termination of reunification services to her without statutory notice and violated her due-

process rights. In her accompanying brief, she acknowledged that the court was statutorily

authorized to transfer temporary or permanent custody to the noncustodial parent on a

finding that it is in the best interest of the children to do so. She argued, however, that

Arkansas Code Annotated section 9-27-327(a)(1)(B)(iv)(b) (Supp. 2023) provides that “an

order of a transfer of custody to the non-custodial parent does not relieve the Department

of Human Services of the responsibility to provide services to the parent from whom custody

was removed, unless the court enters an order to relieve the department of the

responsibility.” She urged that because DHS asked the court to close the case after it had

placed the children with their father, it was, in effect, “asking to be relieved of providing

reunification . . . services” without timely filing a motion for no-reunification services. The

failure to “provide the required notice” violated her due-process rights, Rodriguez argued.

4 She therefore asked the court to set aside its order to close the case and order DHS to

continue to provide reunification services to her.

DHS responded by noting that Rodriguez acknowledged that a court has the authority

to transfer custody to a noncustodial parent pursuant to section 9-27-327(a)(1)(B)(iv)(a). It

pointed out, however, that nothing in that statute requires a party to file any type of motion

prior to a court’s decision to transfer custody. It added that even if some type of notice were

required, Rodriguez had been told in October 2023 that DHS would be seeking permanent

custody with Lorenzo.2 Accordingly, DHS asked the court to deny Rodriguez’s motion to set

aside.

The circuit court entered an order denying Rodriguez’s motion on December 11, and

Rodriguez timely appealed. She now argues to this court that the circuit court erred in

denying her request for a continuance of the review hearing; in addition, she asserts that the

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