In re L.C.

CourtCourt of Appeals of Kansas
DecidedDecember 12, 2025
Docket129087
StatusUnpublished

This text of In re L.C. (In re L.C.) 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 L.C., (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 129,087

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

In the Interest of L.C., a Minor Child.

MEMORANDUM OPINION

Appeal from Geary District Court; AMY CRAWFORD-COPPOLA, magistrate judge. Submitted without oral argument. Opinion filed December 12, 2025. Affirmed.

Laura E. Poschen, of Poschen Law, LLC, of Wichita, for appellant natural mother.

Krista Blaisdell, county attorney, for appellee.

Before CLINE, P.J., BRUNS and COBLE, JJ.

PER CURIAM: Mother appeals the termination of her rights to parent her child, L.C., after L.C. was designated as a child in need of care (CINC). Mother claims that insufficient evidence supports the district court's findings of unfitness and that termination is not in L.C.'s best interests. Based on our review of the record, we find no error and affirm the court's termination decision.

FACTUAL AND PROCEDURAL BACKGROUND

L.C. and his sister S.L. were placed in protective custody after the police discovered fentanyl, methamphetamine, and other drugs and paraphernalia in Mother's home. Mother and her boyfriend were arrested and charged with child endangerment and drug possession. Once taken into custody, it was discovered that L.C. suffered from poor

1 dental hygiene that needed to be addressed by a specialist. There were also concerns about physical abuse by Mother's boyfriend.

The State filed a petition on June 1, 2023, to adjudicate L.C. as a child in need of care. Almost eight weeks later, on July 26, 2023, Mother entered a no contest statement to the allegations in the petition. The district court found L.C. to be a child in need of care and approved a reintegration plan that contained several goals for Mother to complete, designed to reintegrate her with L.C. The target date for completion of this plan was December 8, 2023.

In August 2023, Mother overdosed on fentanyl and was hospitalized. After that, she entered a 28-day in-patient rehabilitation. A second case plan was made on December 6, 2023, with similar requirements as the first, but it added a drug evaluation because of her overdose. The second plan had a target completion date of May 24, 2024.

During November 2023, Mother relapsed and tested positive for alcohol, fentanyl, and methamphetamine. Then again in December 2023, Mother tested positive for methamphetamines. In addition to her drug use, Mother was scheduled for a defibrillator placement in January 2024. Mother continued to have positive drug tests between December 2023 and July 2024, but this time most of the tests were positive for either benzodiazepines or oxycodone. Mother also had some negative test results during this time.

As of February 7, 2024, L.C. was living with his paternal grandmother. L.C. was reported as doing very well under her care. The case team noted Mother was sensitive to L.C.'s needs during her visits with him and that she really loved him. But it also noted Mother admitted she was still using drugs and she had yet to complete a second drug and alcohol intake after her relapse. As for Mother's physical health, the case team noted Mother had several health concerns, including congestive heart failure that prevented her

2 from working. As of April 3, 2024, Mother had been unable to advance beyond supervised visits with L.C., limited to one hour per week, and she continued to fail random drug tests.

On April 26, 2024, the State moved to terminate both parents' parental rights. By the termination hearing in October 2024, Mother had pled guilty to fentanyl distribution and was incarcerated with a potential release date in 2027. Before Mother was incarcerated, she claimed that she had been using fentanyl approximately 10 to 12 times a day and that the last time she used it was on the day of her arrest, August 15, 2024. She also reported using methamphetamine two to three times per week up to June 2024.

L.C.'s biological father, who was incarcerated, relinquished his parental rights. So the evidence at the hearing focused on Mother. The case manager, who had overseen the case since L.C. was admitted into protective custody, testified about Mother's efforts. She acknowledged that Mother had completed parenting classes but pointed out her failure to complete several other case plan tasks, including obtaining a mental health evaluation and a second drug and alcohol evaluation. In the case manager's opinion, reunification was not achievable and it was in L.C.'s best interests to continue his placement with his paternal grandmother.

Mother also testified. She explained how she had been making progress towards sobriety in jail, including receiving a job offer, completing NA/AA meetings, attending church, and participating in choir. Mother said she did not consider herself to have a drug problem because she realized she needed to improve her health. She wanted to make sure she could be healthy and sober for her kids. When asked about her health problems she explained she has congestive heart failure and stage 4 cirrhosis of the liver and is hypokalemic, but claimed she is stable now. Mother said she wanted to be in L.C.'s life and have stability once she was released.

3 The district court ultimately decided to terminate Mother's parental rights. It found clear and convincing evidence that Mother was presently unfit and unfit for the foreseeable future due to her drug use, incarceration, and inability to complete a case plan. The district court also found termination was in L.C.'s best interests because L.C. should not have to wait for Mother any longer.

Mother timely appeals.

REVIEW OF MOTHER'S APPELLATE CHALLENGES

I. The district court did not err in terminating Mother's parental rights because the State met its burden of clear and convincing evidence in showing Mother was presently unfit and that she would remain unfit for the foreseeable future.

Mother contends clear and convincing evidence does not support the district court's findings because: (1) Mother completed remedial measures to address her drug problem before her incarceration and continued to participate in drug treatment while incarcerated; (2) Mother's incarceration is not an automatic and exclusive basis for a court's finding of unfitness in the foreseeable future; and (3) the evidence did not show Mother failed to adjust her circumstances or to follow through with a reasonable integration plan.

Standard of Review and Relevant Legal Framework

A person has a constitutionally recognized right to a parental relationship with their child. See In re B.D.-Y., 286 Kan. 686, 697-98, 187 P.3d 594 (2008). Accordingly, the State may extinguish the legal bond between a parent and child only upon clear and convincing proof of parental unfitness. K.S.A. 38-2269(a); In re R.S., 50 Kan. App. 2d 1105, Syl. ¶ 1, 336 P.3d 903 (2014). The Legislature has enacted the Revised Kansas Code for Care of Children, K.S.A. 38-2201 et seq., to codify processes for finding

4 children in need of care, for fostering family reunification, and for terminating parental rights if those efforts fail.

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