In Re: Kaitlyn Layne Boyd Cobb Applying for Intra Family Adoption of A.E.C.

CourtLouisiana Court of Appeal
DecidedNovember 15, 2023
Docket55,401-JAC
StatusPublished

This text of In Re: Kaitlyn Layne Boyd Cobb Applying for Intra Family Adoption of A.E.C. (In Re: Kaitlyn Layne Boyd Cobb Applying for Intra Family Adoption of A.E.C.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Kaitlyn Layne Boyd Cobb Applying for Intra Family Adoption of A.E.C., (La. Ct. App. 2023).

Opinion

Judgment rendered November 15, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,401-JAC

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

IN RE: KAITLYN LAYNE BOYD COBB APPLYING FOR INTRA FAMILY ADOPTION OF A.E.C.

Appealed from the Fifth Judicial District Court for the Parish of West Carroll, Louisiana Trial Court No. 332

Honorable John Clay Hamilton, Judge

THE LOWERY LAW FIRM Counsel for Appellant, By: Scotty Wayne Lowery Kaitlyn Layne Boyd Cobb

BARRY W. DOWD, APLC Counsel for Intervenor- By: Barry W. Dowd Appellee, Shelby Danyell Smith

Before STEPHENS, THOMPSON, and HUNTER, JJ. HUNTER, J.

Plaintiff, Kaitlyn Layne Boyd Cobb, appeals the trial court’s ruling

denying her petition for intrafamily adoption and her motion for new trial.

The trial court concluded the mother of the child met her burden of proving

just cause for her failure to provide financial support and to visit and/or

communicate with the child for a period of at least six months. For the

following reasons, we affirm.

FACTS

Defendant, Shelby Danyelle Smith (“the mother”) and Landon Tylar

Cobb (“the father”), are the parents of A.E.C, born December 16, 2011. At

the time of A.E.C.’s birth, the mother was 14 years old, and the father was

17 years old. The mother has struggled with substance abuse issues and has

been incarcerated for drug-related offenses.

In 2016, the father was granted sole custody of A.E.C., and the mother

was granted limited supervised visitation at the father’s discretion. The

judgment further provided as follows:

*** [A]ny visitation with the child, of any type, by [the mother] is contingent upon her enrollment in, and successful completion of, a drug and alcohol treatment program and random drug screenings through Northeast Louisiana Substance Abuse program in Oak Grove, Louisiana; and, should she fail to enroll in and successfully complete such a substance abuse program, or test positive at any time for illegal or illicit drugs, then any rights to visitation by her shall be terminated without further order of the Court[.] ***

The mother was also ordered to “ensure that all documentation of any

drug screen or substance abuse program and all drug screen results be

furnished to counsel for [the father].” Further, the mother was ordered to

pay child support in the amount of $150 per month, in addition to arrears. The mother was incarcerated when the judgment was entered. Additionally,

the father was represented by counsel during the custody proceedings, but

the mother was not.1

In 2017, the father began cohabiting with Kaitlyn Layne Boyd Cobb

(“the stepmother”), and the couple married on December 11, 2021. Soon

thereafter, on December 22, 2021, the stepmother filed a petition for the

intrafamily adoption of A.E.C., alleging, inter alia, the mother had not

provided financial support for the child in more than six months; the mother

had not visited or communicated with the child in more than six months; the

child had been living with her (the stepmother) for at least six months prior

to the filing of the petition for adoption; the mother had forfeited her right to

consent to the adoption; and it was in the best interest of the child to grant

the petition for adoption. The father signed an affidavit concurring with the

petition for adoption.

On February 14, 2022, a hearing on the adoption petition was held.

The father and stepmother were represented by counsel, and the mother was

unrepresented. The trial court determined it was in the best interest of the

child for the adoption to proceed and granted the petition for adoption. The

1 The judgment provided:

PLEASE SEND JUDGMENT and NOTICE OF JUDGMENT TO:

[The mother] 131 Taylor Steet Oak Grove, Louisiana 71263

OR

Morehouse Parish Jail

However, there is no indication of record the mother was ever served with the judgment or notice of judgment.

2 court signed a judgment terminating the parental rights of the mother and

granting a final decree of adoption. The mother appealed, and this Court

vacated the judgment, finding the mother had not been served with notice as

mandated by La. Ch. C. art. 1247. In re Boyd for Intra Fam. Adoption of

A.E.C., 54,807 (La. App. 2 Cir. 9/21/22), 349 So. 3d 1035.

Following remand, a hearing was held. After hearing the testimony

and reviewing the evidence, the trial court found the mother failed to comply

with the court order to pay child support and failed to visit and/or

communicate with the minor child for a period of at least six months.

However, the court denied the petition for adoption, finding the mother met

of burden of proving just cause for her failures. The trial court stated:

[B]ased on the testimony and the exhibits introduced, consisting primarily of phone messages and text messages attempted by the mother, Shelby Smith, to communicate with the child, this Court finds that the mother has met her burden by a preponderance of the evidence, in establishing just cause for her failure to provide support or communicate with the child. This finding is based on the numerous and consistent attempts that the mother, Shelby Smith, made to establish communication with the child through phone conversations and text messages which were, for the most part, consistent and persistent subsequent to her release from prison. While this Court firmly believes that the mother’s attempts to establish communication could have been more substantial, the Court finds that the low threshold of her burden, being only a preponderance of the evidence, has been established.

Thereafter, the stepmother filed a motion for new trial arguing the trial

court “dispensed with the issue of ‘best interest’ and thus disposed of the

entire adoption proceeding, thereby bypassing the need for an evidentiary

hearing in accordance with La. Ch. C. 1253[.]” The stepmother also argued

the court erred in failing to consider the child’s wishes. Further, the

stepmother took issue with the legal representation provided by the attorney

3 appointed to represent the child. According to the stepmother, the attorney

did not “make contact with the family or interview the child prior to the

hearing, did not examine or cross-examine any witnesses, called no

witnesses on behalf of the child, and offered up no report on behalf of the

child.” The trial court denied the stepmother’s motion for new trial, stating:

*** [B]ecause this Court found that the mother’s consent to the adoption was required, and that she had not executed an act of surrender nor had her parental rights been involuntarily terminated, that the Petition for Intra-Family Adoption should be dismissed, with no need to proceed to a “best interest” hearing. ***

The stepmother appeals.

DISCUSSION

The stepmother contends the trial court erred in denying her petition

for intrafamily adoption. She argues she met her burden of proving the

mother had not communicated with the child or paid child support for a

period of at least six months; therefore, she made a prima facie showing the

mother’s consent to the adoption was not necessary. The stepmother further

contends the burden shifted to the mother to show her failure was due to

factors beyond her control, and she failed to meet that burden. Additionally,

the stepmother asserts the trial court erred in refusing to make a

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Related

In re Puckett
137 So. 3d 1264 (Louisiana Court of Appeal, 2014)
In re B.J.C. Applying for Intrafamily Adoption
206 So. 3d 337 (Louisiana Court of Appeal, 2016)

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Bluebook (online)
In Re: Kaitlyn Layne Boyd Cobb Applying for Intra Family Adoption of A.E.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-kaitlyn-layne-boyd-cobb-applying-for-intra-family-adoption-of-aec-lactapp-2023.