In re A.L.E.A.

CourtCourt of Appeals of Kansas
DecidedJune 16, 2017
Docket116276
StatusUnpublished

This text of In re A.L.E.A. (In re A.L.E.A.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re A.L.E.A., (kanctapp 2017).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 116,276

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

In the Interest of A.L.E.A., A Minor Child.

MEMORANDUM OPINION

Appeal from Butler District Court; MICHAEL E. WARD, judge. Opinion filed June 16, 2017. Affirmed.

Joshua S. Andrews, of Cami R. Baker & Associates, P.A., of Augusta, for appellant.

Cheryl M. Pierce, assistant county attorney, for appellee State of Kansas.

Before GARDNER, P.J., PIERRON, and ATCHESON, JJ.

Per Curiam: A.A. appeals the decision of the Butler County District Court to terminate his rights as the father of A.L.E.A., his 10-year-old daughter, because of his extended incarceration and her pronounced emotional problems. We find sufficient evidence supports the district court's determination and reject A.A.'s additional challenge suggesting issue preclusion somehow barred the ruling. We, therefore, affirm the termination of A.A.'s parental rights.

FACTUAL AND PROCEDURAL HISTORY

A.A. was taken into federal custody on drug charges before A.L.E.A. was born. He was convicted on those charges and at the time of the final termination hearing in this case remained in prison serving his sentence. Raised by her mother, A.L.E.A. was

1 subjected to physical and sexual abuse while in her custody. The State filed a petition in October 2012 to have A.L.E.A. declared a child in need of care. The district court adjudged A.L.E.A. to be in need of care and placed her in temporary state custody. A.A. has been represented by court-appointed lawyers throughout this case and has participated in the hearings by telephone from the various federal prisons where he has been held. Mother has relinquished her parental rights and is not a party to this appeal.

The record evidence in the case shows A.L.E.A. has been diagnosed as having posttraumatic stress disorder and disruptive mood dysregulation disorder. The latter is a comparatively new psychological diagnosis applied when a child displays severe, chronic irritability and frequently reacts with explosive anger to situations that typically should prompt only mild or no emotional responses. Those episodes may include physically aggressive behavior, as they sometimes have with A.L.E.A. In short, A.L.E.A. manifests a fairly pronounced constellation of emotional issues making her difficult to manage in a family setting.

In February 2014, the State filed its first motion to terminate parental rights, alleging A.A. was unfit because of his extended incarceration and because he had been found unfit in another court proceeding involving a different child. After an evidentiary hearing, the district court ruled A.A. to be unfit and determined the unfitness was unlikely to change in the foreseeable future. But the district court found that terminating A.A.'s parental rights would not be in A.L.E.A.'s best interests and, therefore, denied the State's motion. The district court wanted the assigned case manager and the social service agency overseeing A.L.E.A.'s care to explore a permanent custodianship for A.L.E.A. with her paternal aunt.

About 21 months later, the State filed a second motion to terminate A.A.'s parental rights, alleging the same bases for unfitness. A.A. argued that collateral estoppel precluded the successive motion, since the district court had already declined to terminate

2 his rights. The State argued the factual circumstances had changed, so the new motion was not barred as repetitive. The district court rejected A.A.'s argument and held a new evidentiary hearing in January 2016.

The evidence showed that A.A. remained in federal custody and was not likely to be released from prison for at least a year. During the early part of his imprisonment, A.A. had some limited visits with A.L.E.A., when she came to the facility where he was being held and would see him several days in a row. Later, A.A. had regular telephone conversations with A.L.E.A. But those calls were stopped at the request of a foster placement who said A.L.E.A. tended to act out after talking with her father. The district court questioned the basis for and the wisdom of the decision cutting off communication between A.A. and A.L.E.A.

A.L.E.A. has been unsuccessfully placed with several foster families. Those placements failed largely because of A.L.E.A.'s emotional issues. A.L.E.A. also lived briefly with her aunt's family, and that didn't work out for essentially the same reason. For a time, the social service agency had A.L.E.A. in a series of what are typically considered short term, emergency residential placements. By the time of the second termination hearing, A.L.E.A. had been in an inpatient psychiatric placement for about 4 months but was scheduled to be moved to a less restrictive setting sometimes used with children unsuited for traditional foster placement. That was A.L.E.A.'s second inpatient stay for treatment of her psychological problems.

The therapist working with A.L.E.A. testified that she would ask about her father, wondered why she couldn't talk to him, and wanted to resume telephone calls with him. Other witnesses indicated that A.L.E.A. did not speak of A.A. The therapist said that finding a stable permanent placement for A.L.E.A. was essential to her mental health and that she would not improve and might well regress outside such an environment. He also

3 said anyone adopting or otherwise taking A.L.E.A. on a permanent basis would need to have training in dealing with children who had experienced significant trauma.

The case manager assigned to A.L.E.A. said no potential adoptive parents had been identified and agreed there was no guarantee A.L.E.A. would be adopted. The case manager testified that if A.A.'s parental rights were terminated, the social service agency could work through various "adoption recruiters" who would be able to search nationally for families willing and able to adopt children with special needs, thereby increasing the possibility for an adoptive placement.

The district court again found A.A. to be unfit and that the circumstances would not be likely to change in the foreseeable future. The district court relied on K.S.A. 2016 Supp. 38-2269(b)(5), making a parent's conviction of and incarceration for a felony grounds for unfitness, and on K.S.A. 2016 Supp. 38-2271(a)(1), permitting a district court to presume unfitness in a current proceeding based on a judicial finding of unfitness in an earlier proceeding. Given A.L.E.A.'s circumstances and the failure of the permanent guardianship, the district court found termination of A.A.'s parental rights to be in the child's best interests. The district court entered a termination order. A.A. has appealed.

LEGAL ANALYSIS

On appeal, A.A. challenges the sufficiency of the evidence to support the district court's finding of unfitness and its conclusion that termination was in A.L.E.A.'s best interests. A.A. also contends that collateral estoppel barred the State from filing a second motion to terminate his parental rights in light of the ruling on the first one. After setting forth key legal principles governing proceedings to terminate parental rights, we take up those points in order.

4 Governing Legal Principles

A parent has a constitutionally protected liberty interest in the relationship with his or her child. See Santosky v. Kramer, 455 U.S. 745, 753, 759-60, 102 S. Ct. 1388, 71 L. Ed. 2d 599 (1982); In re B.D.-Y., 286 Kan.

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