In the Interest Of: E. E. B. W.

CourtCourt of Appeals of Georgia
DecidedOctober 17, 2012
DocketA12A1468
StatusPublished

This text of In the Interest Of: E. E. B. W. (In the Interest Of: E. E. B. W.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest Of: E. E. B. W., (Ga. Ct. App. 2012).

Opinion

FOURTH DIVISION DOYLE, P. J., ANDREWS and BOGGS, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

October 17, 2012

In the Court of Appeals of Georgia A12A1468. In the Interest of E. E. B. W., a child.

ANDREWS, Judge.

At issue is whether the Fulton County Juvenile Court properly exercised

subject matter jurisdiction to terminate the parental rights of the adoptive parents of

a minor child born in and a citizen of Zambia, but who, at the time of the termination

proceedings, had lived in Fulton County for at least six consecutive months with

persons acting as her parents. On appeal from the order terminating their parental

rights, the adoptive parents contest only the Juvenile Court’s subject matter

jurisdiction – they do not claim that the Court lacked personal jurisdiction over them

or the child, nor do they claim that the evidence introduced at the termination

proceeding was insufficient under OCGA § 15-11-94 to support termination of their

parental rights. We find that the Juvenile Court properly exercised subject matter jurisdiction over the termination proceedings pursuant to OCGA § 15-11-28 and the

Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) (OCGA § 19-9-

40 et seq.). Accordingly, we affirm the Court’s order terminating parental rights.

The child was born in Zambia in June of 1997 and was almost 14 years old at

the time of the June 2011 termination order. Orphaned at a young age, the child lived

at an orphanage in Zambia and suffered from extensive facial deformities after a

tumor caused by measles was removed from her face. The orphanage sought medical

treatment for the child and in 2004 arranged for a medical charity, Childspring

International, to sponsor the child’s travel to Atlanta, Georgia to receive surgical and

other medical treatment to correct her facial deformities. Pursuant to this

arrangement, Childspring placed the child with a host family where the child has

resided in Fulton County since 2005 while undergoing multiple surgeries and other

medical treatment. Additional surgery is still necessary. In 2005, while the child was

absent from Zambia, the married couple who operate the orphanage and claim dual

United States and Zambian citizenship, adopted the then 8-year-old child in Zambia

without notice or knowledge of the child. In 2006, the child made an outcry to

medical providers that the couple (the adoptive parents pursuant to the Zambian

adoption) and others had sexually abused her while she lived at the orphanage

2 operated by the couple in Zambia. Based on the allegations of sexual abuse, the

Fulton County Department of Family and Children Services took the child into

protective custody, investigated the allegations, and brought deprivation proceedings

in June 2006. The Fulton County Juvenile Court adjudicated the child deprived in

July 2007 and placed the child in the legal custody of the Department, which placed

the child in foster care with the same host family that the child had lived with in

Fulton County since 2005. The adoptive parents appeared at the deprivation

proceedings, stipulated that the child was deprived, but denied any inappropriate

sexual contact with the child. Subsequent to the Juvenile Court’s order finding that

the child was deprived, the adoptive parents did not appeal, did not complete the

court-ordered plan for reunification with the child, provided no financial support for

the child, and failed to maintain any contact with the Department concerning the child

for three years prior to the termination of their parental rights in June 2011.

The adoptive parents contend that the UCCJEA provides that the Fulton

County Juvenile Court lacked subject matter jurisdiction to consider proceedings to

terminate their parental rights, and that Zambia has subject matter jurisdiction. To the

contrary, we find no basis under the UCCJEA to conclude that subject matter

jurisdiction in this case rests in Zambia.

3 A county juvenile court generally has exclusive original jurisdiction over child

deprivation proceedings and subsequent termination of parental rights proceedings

concerning a child present within the county. OCGA §§ 15-11-28; 15-11-29 (a). With

respect to interstate child custody disputes, the jurisdictional rules of the UCCJEA

also apply to “child custody determination[s]”1 made in a wide range of “child

custody proceeding[s]” defined to include not only “a proceeding in which legal

custody, physical custody, or visitation with respect to a child is an issue,” but also

“a proceeding for divorce, separation, neglect, abuse, dependency, guardianship,

paternity, termination of parental rights, and protection from family violence, in

which the issue may appear.”2 OCGA § 19-9-41 (3), (4). Accordingly, jurisdictional

rules of the UCCJEA apply to both child deprivation proceedings in which the issue

of “neglect” or “abuse” appears, and “termination of parental rights” proceedings. Id.

The UCCJEA does not, however, govern adoption proceedings. OCGA § 19-9-42.

1 “‘Child custody determination’” means a judgment, decree, or other order of a court providing for the legal custody, physical custody, or visitation with respect to a child. The term includes a permanent, temporary, initial, and modification order. The term does not include an order relating to child support or other monetary obligations of an individual.” OCGA § 19-9-41 (3). 2 “[Child custody proceeding] does not include a proceeding involving juvenile deliquency, contractual emancipation, or enforcement under Part 3 of this article [OCGA §§ 19-9-81 thru 19-9-97].”

4 Moreover, under the UCCJEA, “a foreign nation is treated in the same manner as

would be a sister state of the United States . . . [and] [a] foreign child custody

determination must be enforced if it was made ‘under factual circumstances in

substantial conformity with the jurisdictional standards’ of the UCCJEA. OCGA §

19-9-44 [(a),] (b).” Bellew v. Larese, 288 Ga. 495, 497-498 (706 SE2d 78) (2011).

Under the UCCJEA, a state, including a foreign country, has subject matter

jurisdiction to make an initial child custody determination if it is the child’s “home

state” on the date the child custody proceedings are commenced. OCGA § 19-9-61

(a) (1). The child’s “home state” is defined as

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Related

Bellew v. Larese
706 S.E.2d 78 (Supreme Court of Georgia, 2011)

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