Jessica Anderson v. Cabinet for Health and Family Services

CourtCourt of Appeals of Kentucky
DecidedMarch 24, 2022
Docket2020 CA 000057
StatusUnknown

This text of Jessica Anderson v. Cabinet for Health and Family Services (Jessica Anderson v. Cabinet for Health and Family Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jessica Anderson v. Cabinet for Health and Family Services, (Ky. Ct. App. 2022).

Opinion

RENDERED: MARCH 25, 2022; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-0057-MR

JESSICA ANDERSON APPELLANT

APPEAL FROM MEADE CIRCUIT COURT v. HONORABLE KENNETH H. GOFF, II, JUDGE ACTION NO. 19-CI-00056

CABINET FOR HEALTH AND FAMILY SERVICES; AND BRITTANY WINSOR APPELLEES

AND

NO. 2020-CA-0059-MR

APPEAL FROM MEADE CIRCUIT COURT v. HONORABLE KENNETH H. GOFF, II, JUDGE ACTION NO. 19-CI-00056

CABINET FOR HEALTH AND FAMILY SERVICES; AND BRITTANY WINSOR APPELLEES OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, JONES, AND McNEILL, JUDGES.

McNEILL, JUDGE: Jessica Anderson (mother) brings these consolidated appeals

from a December 10, 2019 order dismissing her petition for immediate entitlement

to custody of her minor child, K.N.E., and a separate order entered on December

10, 2019, denying her motion to recuse. We affirm.

I. BACKGROUND

Mother is the biological mother of two children, K.N.E. (D.O.B. April

11, 2012) and V.K. (D.O.B. August 26, 2018). Each child has been the subject of

several proceedings in Meade District and Circuit Courts. The instant appeal

concerns Meade Circuit Court case number 19-CI-00056, a petition for immediate

entitlement to custody filed by mother against appellees Cabinet for Health and

Family Services (the Cabinet) and Brittany Winsor (Winsor) pursuant to KRS1

620.110. While the petition was filed as to both children, for reasons not relevant

to this Opinion, this appeal concerns only K.N.E.

K.N.E. has been the subject of two dependency proceedings in Meade

District Court as well as a separate Meade Circuit Court action, case number 17-

1 Kentucky Revised Statutes.

-2- CI-00372, in which Winsor was first designated as her de facto custodian. None of

these cases is before this Court. The sole issue before us is whether the circuit

court erred in its handling of mother’s KRS 620.110 petition.

The dependency proceedings concerning K.N.E. have a complex

procedural history which we need not recount in their entirety. Mother’s KRS

620.110 petition concerned an order entered by the district court on October 31,

2018 removing K.N.E.’s maternal grandmother, Michelle Anderson, as her

temporary custodian and replacing her with Winsor. The district court’s order did

not address the rights of mother, who had already lost temporary custody of K.N.E.

but retained visitation rights.

The Cabinet filed a second dependency case concerning K.N.E. on

November 22, 2018.2 On December 4, 2018, the district court entered an order

mirroring the orders in place in the first dependency case. Ultimately, the district

court scheduled an adjudication hearing on custody for March 28, 2019.

Mother filed the petition underlying this appeal in circuit court on

March 13, 2019. No other action was taken in the case prior to the March 28, 2019

hearing in the district court dependency case. The district court issued an

adjudication order in the dependency case on March 29, 2019, finding that K.N.E.

2 The Cabinet’s reasons for doing so are not clear from the record.

-3- was a neglected or abused child, and granting Winsor custody. On September 12,

2019, the district court entered a consistent disposition order.

After the final adjudication of the district court case, mother moved

the circuit court in the instant case for a default judgment, as neither the Cabinet

nor Winsor had filed an answer. Winsor took the position that this proceeding was

moot, as the temporary orders which formed the basis of the action had been

subsumed by the September 12, 2019 disposition order. On December 10, 2019,

the circuit court in the instant matter entered a final order denying mother’s motion

for default (“as the [circuit court] no longer has authority to grant the relief

sought”), and dismissing the matter, with prejudice.

Mother also moved for the recusal of Judge Kenneth H. Goff, II as he

had previously presided over related cases as a district judge. That motion was

also denied. This appeal follows.

II. ANALYSIS

Today we are called upon to review the very limited question before

us – whether the circuit court correctly dismissed the underlying action as moot in

the face of mother’s motion for default. In this limited sense, there is a case or

controversy before us. See Louisville Transit Co. v. Dept. of Motor Transp., 286

S.W.2d 536, 537 (Ky. 1956) (“The circuit court dismissed the appeal because the

-4- court was of the opinion that the issues raised . . . were moot. Accordingly, our

review is limited to this aspect of the case.”).

A petition for immediate entitlement to custody is a statutory cause of

action. KRS 620.110 provides:

Any person aggrieved by the issuance of a temporary removal order may file a petition in Circuit Court for immediate entitlement to custody and a hearing shall be expeditiously held according to the Rules of Civil Procedure. During the pendency of the petition for immediate entitlement the orders of the District Court shall remain in effect.

Under its plain terms, KRS 620.110 concerns relief from a temporary

order of the district court. “The clear object of the statute is to permit parents to

seek relief from a temporary order.” C.K. v. Cabinet for Health and Family

Services, 529 S.W.3d 786, 789 (Ky. App. 2017). The statutory mechanism is

necessary because a temporary custody order is interlocutory and therefore cannot

be reviewed under an ordinary appellate process. B.D. v. Cabinet for Health and

Family Services, 426 S.W.3d 621, 622 (Ky. App. 2014). Once a temporary

custody order is superseded by a final and appealable order of the court, KRS

620.110 is of no utility. An aggrieved party then has a right to a direct appeal. In

dependency, neglect, and abuse (DNA) cases, the disposition order is the final

order from which an appeal may be taken. J.E. v. Cabinet for Health and Family

Services, 553 S.W.3d 850, 852 (Ky. App. 2018).

-5- “[A] petition for immediate entitlement to custody . . . provides [a

tool] to parents who are unhappy with a district or family court’s decision

regarding temporary custody following a temporary removal hearing.” C.K., 529

S.W.3d at 789.

KRS 620.110 petitions “are not considered appeals of the temporary

order of removal, however, but are considered original actions ‘in the nature of

habeas corpus.’” C.K., 529 S.W.3d at 789 (quoting B.D., 426 S.W.3d at 623). By

necessity, these proceedings are somewhat truncated. Specifically, the statute

requires the circuit court to “expeditiously” conduct a hearing on the petition.3 It is

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Related

Louisville Transit Co. v. Department of Motor Transportation
286 S.W.2d 536 (Court of Appeals of Kentucky (pre-1976), 1956)
James v. Wilson
95 S.W.3d 875 (Court of Appeals of Kentucky, 2002)
B.D. v. Commonwealth, Cabinet for Health & Family Services
426 S.W.3d 621 (Court of Appeals of Kentucky, 2014)
C.K. v. Cabinet for Health & Family Services
529 S.W.3d 786 (Court of Appeals of Kentucky, 2017)
J.E. v. Cabinet for Health & Family Servs.
553 S.W.3d 850 (Court of Appeals of Kentucky, 2018)

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Bluebook (online)
Jessica Anderson v. Cabinet for Health and Family Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jessica-anderson-v-cabinet-for-health-and-family-services-kyctapp-2022.