J.R.M. v. Warren County Department of Child Protection Services By Andrea A. Sanders, and S.M.M., A Minor, By and Through Their Next Friend, Andrea A. Sanders and Mississippi Department of Child Protection Services

CourtCourt of Appeals of Mississippi
DecidedMarch 31, 2026
Docket2024-CA-00984-COA
StatusPublished

This text of J.R.M. v. Warren County Department of Child Protection Services By Andrea A. Sanders, and S.M.M., A Minor, By and Through Their Next Friend, Andrea A. Sanders and Mississippi Department of Child Protection Services (J.R.M. v. Warren County Department of Child Protection Services By Andrea A. Sanders, and S.M.M., A Minor, By and Through Their Next Friend, Andrea A. Sanders and Mississippi Department of Child Protection Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.R.M. v. Warren County Department of Child Protection Services By Andrea A. Sanders, and S.M.M., A Minor, By and Through Their Next Friend, Andrea A. Sanders and Mississippi Department of Child Protection Services, (Mich. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2024-CA-00984-COA

J.R.M. APPELLANT

v.

WARREN COUNTY DEPARTMENT OF CHILD APPELLEES PROTECTION SERVICES BY ANDREA A. SANDERS, AND S.M.M., A MINOR, BY AND THROUGH THEIR NEXT FRIEND, ANDREA A. SANDERS AND MISSISSIPPI DEPARTMENT OF CHILD PROTECTION SERVICES

DATE OF JUDGMENT: 07/30/2024 TRIAL JUDGE: HON. MARCIE TANNER SOUTHERLAND COURT FROM WHICH APPEALED: WARREN COUNTY YOUTH COURT ATTORNEY FOR APPELLANT: JERRY CAMPBELL ATTORNEYS FOR APPELLEES: OFFICE OF THE ATTORNEY GENERAL BY: KRISTI DUNCAN KENNEDY LINDSEY ETHERIDGE LAZINSKY BRANDON COLLIN SMITH KIMBERLY GOLDEN GORE NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: AFFIRMED - 03/31/2026 MOTION FOR REHEARING FILED:

BEFORE WILSON, P.J., WESTBROOKS AND LAWRENCE, JJ.

WILSON, P.J., FOR THE COURT:

¶1. J.M. appeals from a judgment of the Warren County Youth Court terminating his

parental rights on five different statutory grounds. J.M. argues that substantial evidence does

not support the youth court’s findings. However, applying our limited, deferential standard

of review, we find no reversible error and affirm.

FACTS AND PROCEDURAL HISTORY ¶2. S.M., a male child, was born in May 2022.1 J.M. is S.M.’s father, and C.S. is his

mother. J.M. was incarcerated shortly after S.M.’s birth.2 On June 1, 2022, the Warren

County Youth Court placed S.M. in the care and custody of the Mississippi Department of

Child Protection Services (CPS). The youth court placed S.M. in CPS custody because the

court had already adjudicated S.M.’s half-sister, N.S., to be a neglected child and placed N.S.

in CPS custody due to, inter alia, drug use by C.S. and N.S.’s father.3

¶3. On June 10, 2022, J.M. signed a family service plan with the goal of reunification.

The plan required that J.M. “obtain and maintain [a] suitable living [environment] for his

child,” “cooperate and submit to random drug screens,” “submit to a drug assessment,”

“comply [with] and successfully attend parenting/anger management classes as scheduled at

the CAP Center,” “ensure that he can financially provide basic needs for his child,” and “visit

with his son at least twice monthly.”

¶4. At an adjudication hearing in July 2022, the youth court adjudicated S.M. to be

neglected. In a disposition hearing the same day, the court found that reunification with J.M.

was in S.M.’s best interest and adopted a permanency plan requiring CPS to make reasonable

efforts toward reunification. The court adopted a concurrent plan of custody with a relative.

1 We use initials to protect the privacy of minors. 2 J.M. was in custody for motor vehicle theft. Later, he was indicted in a separate case for possession of burglary tools. C.S. also faced multiple criminal charges and was in and out of jail in Warren County and Rankin County between the time S.M. was born and the final hearing in this case. 3 N.S. was three years old and had been in CPS custody since August 2021. J.M. is not N.S.’s father, and N.S. is not at issue in this appeal. N.S.’s father died from injuries he sustained in a car wreck the day after N.S. was adjudicated to be a neglected child.

2 S.M. was placed in the care of N.S.’s foster parents.

¶5. J.M. pled guilty to motor vehicle theft in September 2022 and was admitted to a drug

court program. In June 2023, the youth court held a permanency hearing. C.S. tested

positive for amphetamines and methamphetamine, while J.M. tested negative for drugs. J.M.

testified that he was going to help C.S. overcome her drug addiction, and he asked the court

to give her more time. The court adopted a permanency plan of terminating C.S.’s parental

rights but ordered CPS to continue working with J.M. toward reunification.

¶6. In October 2023, the court held a permanency hearing, and C.S. again tested positive

for amphetamines and methamphetamine. J.M. tested negative for drugs. According to the

court-appointed guardian ad litem (GAL), Leigh Ann Cade, J.M. had been warned that his

continued association with C.S. could affect his participation in drug court and ability to get

custody of his son. However, J.M. “felt like he needed to support [C.S.].” The youth court

found that CPS had made reasonable efforts to assist J.M. in complying with this service plan

and that J.M. had failed to comply. Therefore, the court adopted a new permanency plan for

S.M. of terminating J.M.’s parental rights and adoption, and the court directed CPS to initiate

the process of filing a petition to terminate J.M.’s parental rights.

¶7. In November 2023, CPS filed a petition to terminate J.M.’s and C.S.’s parental rights

to S.M.4 The petition alleged that (1) S.M. had been adjudicated a neglected child; (2) S.M.

had been in CPS’s custody for at least six months; (3) the court had conducted a permanency

hearing and determined that CPS had made reasonable efforts toward reunification, but the

4 The petition also sought to terminate C.S.’s parental rights as to N.S.

3 parents had failed to substantially comply with their service plan; (4) terminating parental

rights was in S.M.’s best interest; and (5) termination was justified on five distinct statutory

grounds. See Miss. Code Ann. §§ 93-15-115, -119, & -121 (Rev. 2021). On March 20 and

22, 2024, the youth court held a hearing on the petition.

¶8. At the hearing, CPS social worker Nashova Richardson testified that J.M. had

“completed a great deal” of his service plan. Richardson stated that J.M. had submitted to

hair follicle drug testing, submitted to a drug assessment, completed an anger management

class, and shown that he could financially meet S.M.’s basic needs. She stated that J.M.

attended supervised visitations with S.M. “whenever he could get off from work,” but she

also testified that J.M. often attempted to visit too late at night or failed to show up to

scheduled visits at all. Richardson testified that J.M. had obtained housing. However,

Richardson had never been able to do a walk-through of the home because she had never

been able to get in touch with J.M. to do a walk-through, and no one was ever at home when

she visited the home. Accordingly, Richardson did not know whether the home was actually

suitable for S.M.

¶9. Richardson testified that reunification between J.M. and S.M. was prevented by J.M.

“maintaining a relationship with [C.S.]” because C.S. “continued to use drugs” while they

continued to “liv[e] in the same home together.” Richardson stated that J.M. had never had

unsupervised visitation with S.M. or been alone with S.M., and this prevented them from

forming any sort of parent-child relationship. Richardson testified that, in her opinion, J.M.

was not willing or able to care for S.M., had not demonstrated a willingness to care for S.M.,

4 and had abandoned or deserted his duties to the child. She believed there had been a

substantial erosion in the relationship between J.M. and S.M. due to J.M.’s insistence on

continuing his relationship with C.S.

¶10. The GAL testified at the hearing that she believed J.M. was unwilling to provide a

drug-free home for S.M. and that there was “a deep-seated erosion of the parent-child

relationship” between J.M. and S.M. She attributed both issues to J.M.’s continued

relationship with C.S. despite C.S.’s continued drug use. The GAL also testified that S.M.’s

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J.R.M. v. Warren County Department of Child Protection Services By Andrea A. Sanders, and S.M.M., A Minor, By and Through Their Next Friend, Andrea A. Sanders and Mississippi Department of Child Protection Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jrm-v-warren-county-department-of-child-protection-services-by-andrea-missctapp-2026.