Jessica Sneed v. Arkansas Department of Human Services and Minor Children

2020 Ark. App. 462, 609 S.W.3d 668
CourtCourt of Appeals of Arkansas
DecidedOctober 7, 2020
StatusPublished

This text of 2020 Ark. App. 462 (Jessica Sneed v. Arkansas Department of Human Services and Minor Children) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jessica Sneed v. Arkansas Department of Human Services and Minor Children, 2020 Ark. App. 462, 609 S.W.3d 668 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 462 Reason: I attest to the accuracy and integrity of this document ARKANSAS COURT OF APPEALS DIVISION I Date: 2021-07-15 10:16:56 Foxit PhantomPDF Version: 9.7.5

No. CV-20-337

Opinion Delivered October 7, 2020 JESSICA SNEED APPELLANT APPEAL FROM THE MADISON V. COUNTY CIRCUIT COURT [NO. 44JV-18-69] ARKANSAS DEPARTMENT OF HUMAN SERVICES AND MINOR CHILDREN HONORABLE STACEY APPELLEES ZIMMERMAN, JUDGE

AFFIRMED

BRANDON J. HARRISON, Judge

The Arkansas Department of Human Services opened this case in 2018 after Jessica

Sneed was arrested on an outstanding warrant for public intoxication and child

endangerment. There was no caretaker available for her five children—DS, SM1, LM1,

SM2, and SM3—when Jessica was arrested. The Madison County Circuit Court

adjudicated the children dependent-neglected for three reasons:

• The children needed extensive dental work that would require surgery; • The children needed counseling, and they had been living in unsafe conditions with their mother; and • DHS had been involved with providing services to the family since June 2014.

Jessica partially complied with court orders to submit to random drug screenings, complete

a psychological evaluation, maintain stable housing and employment, and demonstrate an ability to protect her children. But the circuit court ultimately terminated Jessica’s parental

rights; she appeals.

Jessica does not challenge the statutory grounds that the circuit court used to

terminate her parental rights. She instead argues that the termination of her rights was not

in her children’s best interest. Specifically, she says that there was insufficient evidence for

the court to conclude that her children were at risk of potential harm if returned to her

custody and care. The circuit found by clear and convincing evidence pursuant to Ark.

Code Ann. § 9-27-341(b)(3)(A) (Supp. 2019) that it was in the best interest of the children

to terminate Jessica’s parental rights. It concluded that Jessica had not demonstrated the

ability to protect the children and keep them safe from harm; that the potential of harm was

“too great” to return custody to her; that she had not resolved the issues that caused the

children to come into care; and that it was in the children’s best interest to have a safe and

permanent home. We hold that the court’s decision was not clearly erroneous. See Meredith

v. Ark. Dep’t of Human Servs., 2017 Ark. App. 120, at 3, 513 S.W.3d 909, 911 (explaining

our standard of review and the requirement that the circuit court’s decision must be based

on clear and convincing evidence).

We have reviewed the record anew and will highlight some of the facts that came to

light during the termination hearing. After the children had been removed from Jessica’s

home, a true finding against the oldest child, DS, was entered for sexual abuse of a six-year-

old in his foster home. Seven months into the case, Jessica had not participated in weekly

drug screens, had tested positive for alcohol, had not maintained stable housing or

employment, had not maintained contact with DHS, and had not completed a psychological

2 evaluation. Almost a year into the case, Jessica still was not submitting to weekly drug-and-

alcohol screens but had completed a psychological evaluation, and the court noted that she

had made “some progress.” When the 2019 permanency-planning order was entered, the

court found that “Jessica has not obtained employment, has not submitted to random drug

and alcohol screens. Jessica’s live in fiancé is a registered sex offender.” Jessica remained

unemployed throughout the case and was still unemployed at the time of the termination

hearing.

A DHS caseworker testified that Jessica’s contact with the department and

participation in the case had been “very sporadic,” that she had missed many drug

screenings, and that she had tested positive on a few of the screenings in which she

participated. The caseworker stated the following about Jessica.

She’s not made safe choices for her children whenever she’s married a registered sex offender, knowing that was a huge concern for the Department, and basically choosing that relationship over her relationship with her children. Her own daughter has made sexual abuse allegations against [DS]. And those allegations were found true but exempt due to his age by CACD. And mom does not believe that those allegations are legitimate. She thinks that [DS]1 did not do them. And so that demonstrates to us that if all the children were to return home that mom, not believing that, is not gonna protect the younger girls and keep them safe from harm. Just poor choices.

Testimony at the termination hearing showed that there had been no progress made with

family counseling with Jessica and her four daughters because Jessica would not show up or

would cancel the appointment.

Jessica married David Aggers approximately one month before the termination

hearing. They had been together as a couple before Jessica’s children were removed from

1 DS is male and the oldest child. The younger siblings are female.

3 her custody. David was convicted in 1998 of interstate receipt of child pornography and

there was evidence that he had been classified as “low risk” to reoffend. A sentencing report

in the record describes the facts surrounding his conviction. When he testified at the

termination hearing, David claimed that beer cans found during a DHS home visit were

neither his nor Jessica’s and that Jessica’s positive alcohol test was not her fault but his. David

had custody of his four-year-old daughter that Jessica babysat while he worked as a mechanic

and maintenance electrician. Jessica maintained that David’s income and their home was

large enough to support her and her five children.

Two months before the termination hearing, both Jessica and David underwent

psychological evaluations. David did not meet any criteria for the diagnosis of any mental

disorder, and the testing results showed a strong positive bias. By Jessica’s history and report,

she met the criteria for the diagnosis of posttraumatic-stress disorder, but that conclusion

was not supported by the testing, possibly because of her positive bias. The psychological

examiner noted that Jessica seemed to have low insight and awareness of her own problems

and that “[o]f the skills and capacities normally required for parenting, Mrs. Sneed appears

to have weakness in unsteady employment, dependency on others for housing, and poor

judgment in not paying her fines.” The evaluator recommended that Jessica receive

individual counseling and that she and David engage in “couples therapy” because “their

home will need to be stable and supportive before the children can be returned.”

The CASA reports and other evidence in the case describe behavioral changes and

struggles of the children after visits with Jessica. The DHS employee supervising Jessica’s

visits with the children testified about “really chaotic” events during the visits. She said that

4 Jessica lost track of the four youngest children for what the supervisor considered an

unreasonable amount of time, and the supervisor had to enlist the help of the foster parents.

By all accounts, the children’s behavior had improved and they had benefited from the

medical and mental-health treatments received during their time in foster care.

Jessica offered the court various explanations of why she had missed appointments

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Related

Meredith v. Arkansas Department of Human Services
2017 Ark. App. 120 (Court of Appeals of Arkansas, 2017)

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2020 Ark. App. 462, 609 S.W.3d 668, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jessica-sneed-v-arkansas-department-of-human-services-and-minor-children-arkctapp-2020.