In the Interest of R. E. M. B., a Child (Mother)

CourtCourt of Appeals of Georgia
DecidedMarch 3, 2025
DocketA24A1448
StatusPublished

This text of In the Interest of R. E. M. B., a Child (Mother) (In the Interest of R. E. M. B., a Child (Mother)) 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 R. E. M. B., a Child (Mother), (Ga. Ct. App. 2025).

Opinion

THIRD DIVISION DOYLE, P. J., HODGES and WATKINS, 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. https://www.gaappeals.us/rules

March 3, 2025

In the Court of Appeals of Georgia A24A1448. IN THE INTEREST OF R. E. M. B., a child.

DOYLE, Presiding Judge.

We granted the application for discretionary appeal of R. E. M. B.’s mother to

review her claim that the evidence was insufficient to support the juvenile court’s

termination of her parental rights to R. E. M. B.1 For the reasons that follow, we

affirm.

Construed in favor of the judgment,2 the evidence presented to the juvenile

1 The father did not appeal this termination, and this appeal does not address any issues relating to the father. 2 See In the Interest of D. C. S., 371 Ga. App. 186, 187 (1) (899 SE2d 834) (2024) (“On appeal from an order terminating parental rights, we review the evidence in the light most favorable to the juvenile court’s judgment in order to determine whether any rational trier of fact could have found by clear and convincing evidence that the natural parent’s rights to custody have been lost.”) (punctuation omitted), quoting court shows that R. E. M. B. was born in February 2019. In April 2022, R. E. M. B.

was removed from her mother’s custody after being left unattended in a vehicle for

an hour-and-a-half in 107-degree heat. R. E. M. B. was hospitalized for hyperthermia,

the mother was arrested and charged with aggravated child abuse, and R. E. M. B. was

placed in foster care. One of the conditions of the mother’s bond was no contact with

R. E. M. B.

In May 2022, R. E. M. B. was adjudicated dependant based on the hyperthermia

incident and the mother’s consent. The Division of Family and Children Services

(“DFCS”) issued the mother a reunification plan requiring her to maintain stable

housing and income, pay child support, complete psychological and parental fitness

assessments, take parenting classes, attend therapy, and demonstrate her parental

abilities in supervised visits with R. E. M. B. The mother initially satisfied some of

these requirements, but in October 2022, she was unemployed, had not paid any child

support, and had not had any contact with R. E. M. B. due to her bond condition.

Nevertheless, the mother got the no contact provision of her bond lifted in

February 2023, and she began supervised visits with R. E. M. B. in April 2023;

however, she was still unemployed and had paid no child support. In May 2023, the

In the Interest of E. M., 347 Ga. App. 351, 354 (2) (819 SE2d 505) (2018). 2 mother gave birth to another child. In September 2023, DFCS petitioned to terminate

the mother’s parental rights on the grounds that the mother had subjected R. E. M.

B. to aggravated circumstances related to the 2022 incident, had failed to complete the

requirements of her case plan, including maintaining stable housing and income and

paying child support, had ongoing mental health issues compromising her parenting

abilities, and had no parental bond with R. E. M. B., who had developed a stronger

bond with her foster parents than with the mother.

The juvenile court convened a hearing on the termination petition in January

2024. The mother testified that she had not paid any child support, but contended that

she only had part-time employment making only about $650 per month, which she

admitted was not enough to cover rent and other expenses. She testified that although

her boyfriend provided financial assistance, he did not live with her and wanted no

involvement in the process of regaining custody of R. E. M. B. She also testified that

she was unable to care for R. E. M. B. on her own.

Regarding the mother’s mental health, the juvenile court heard testimony

indicating that the mother was diagnosed with borderline personality disorder with

psychotic features, major depressive disorder, generalized anxiety disorder, and post-

traumatic stress disorder and that the mother was not taking her prescription

3 medications. Among the symptoms of these untreated mental health issues were

blackout spells that could last for days, during which the mother had no recollection

of her actions.3

Regarding R. E. M. B.’s needs, the juvenile court heard testimony that R. E. M.

B. was diagnosed with disinhibited social engagement disorder,4 mixed receptive-

expressive language disorder,5 and global developmental delay. Due to these disorders,

R. E. M. B. required a higher level of supervision than is typical for a child of her age,

and the mother testified that she lacked the capacity to fully handle R. E. M. B.’s

psychological issues.

The family therapist for the mother and R. E. M. B. testified that the mother

3 The mother reported having such an episode when R. E. M. B. was removed from her custody in April 2022. 4 According to the family therapist, disinhibited social engagement disorder refers to a pattern of behavior in which a child actively approaches and interacts with unfamiliar adults and exhibits overly familiar verbal or physical behaviors, diminished or absent checking back with adult caregivers when venturing away, even in unfamiliar settings, and willingness to go with unfamiliar adults with minimal or no hesitation. The family therapist testified that the disorder results from extreme neglect or deprivation, and treating it requires a stable environment, a predictable routine, and a healthy bond with caregivers. 5 According to the family therapist, mixed receptive-expressive language disorder refers to an inability to fully comprehend the words of others and express oneself verbally. 4 had attended only ten of the eighteen scheduled sessions and was late to three of the

sessions she attended. The mother’s irregular attendance record contributed to her

inability to manage R. E. M. B.’s special needs. Additionally, the family therapist

observed that the bond between the mother and R. E. M. B. was compromised to the

extent that the mother often ignored or responded inappropriately to R. E. M. B., and

R. E. M. B. frequently displayed concerning aggressive behaviors toward the mother.

A social worker who performed an assessment of the bond between the mother and

R. E. M. B. echoed these concerns and testified that their bond did not reflect a

healthy parental attachment.

The parental aide tasked with imparting parenting skills to the mother testified

that the mother participated in only five of the approximately nineteen planned home

visits. She testified that during the home visits that did occur, the mother appeared

not to understand or internalize basic instructions. The mother initially was

cooperative in setting up these visits but eventually became unreachable, causing the

services to terminate.

Another parental aide testified that the mother was often late to or missed

supervised visits with R. E. M. B. due to the mother’s confusion. At the visits, the

mother did not consistently provide the structure and individual attention R. E. M. B.

5 needed to develop, and the mother was not able to properly divide her attention

between the newborn and R. E. M. B., attending to one at the expense of the other

when the newborn was present.

R. E. M. B.’s foster mother testified that when R. E. M. B. first came into her

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In the Interest of R. E. M. B., a Child (Mother), Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-r-e-m-b-a-child-mother-gactapp-2025.