King v. Ark. Dep't of Human Servs.

2016 Ark. App. 368
CourtCourt of Appeals of Arkansas
DecidedAugust 31, 2016
DocketCV-16-288
StatusPublished
Cited by2 cases

This text of 2016 Ark. App. 368 (King v. Ark. Dep't of Human Servs.) 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
King v. Ark. Dep't of Human Servs., 2016 Ark. App. 368 (Ark. Ct. App. 2016).

Opinion

Cite as 2016 Ark. App. 368

ARKANSAS COURT OF APPEALS DIVISION II No. CV-16-288

Opinion Delivered AUGUST 31, 2016

HAILEY KING APPEAL FROM THE BENTON COUNTY CIRCUIT COURT APPELLANT [NO. J-2015-398] V. HONORABLE THOMAS E. SMITH, JUDGE ARKANSAS DEPARTMENT OF HUMAN SERVICES AND MINOR AFFIRMED; MOTION TO WITHDRAW CHILD GRANTED

APPELLEES

DAVID M. GLOVER, Judge

Hailey King appeals from the December 29, 2015 order terminating her parental

rights to D.K. (d.o.b. 7-15-2014). Her counsel has filed a brief and motion to withdraw

pursuant to Linker-Flores v. Arkansas Department of Human Services, 359 Ark. 131, 194 S.W.3d

739 (2004), contending there are no meritorious issues that could arguably support the

appeal. The clerk of our court attempted to notify King of her counsel’s actions by sending

her a packet containing the motion, the brief, and a letter informing King she had the right

to file pro se points for reversal. The packet was sent to King’s last known address via

certified mail, but attempts to deliver the packet were not successful. No pro se points have

been filed.

Counsel’s brief contains an abstract and addendum of the trial-court proceedings,

discusses the adverse rulings and the evidence supporting the termination of King’s parental Cite as 2016 Ark. App. 368

rights, and explains why there is no meritorious ground for reversal. We have reviewed the

brief and the record in this case and agree there is no basis upon which to advance a

meritorious argument for reversal.

We review termination-of-parental-rights cases de novo. Hune v. Arkansas Dep’t of

Human Servs., 2010 Ark. App. 543. Termination of parental rights is an extreme remedy

and in derogation of the natural rights of parents, but parental rights will not be enforced to

the detriment or destruction of the health and well-being of the child. Id. Grounds for

termination of parental rights must be proven by clear and convincing evidence. Id. Clear

and convincing evidence is that degree of proof that will produce in the fact-finder a firm

conviction as to the allegation sought to be established. Id. The appellate inquiry is whether

the trial court’s finding that the disputed fact was proven by clear and convincing evidence

is clearly erroneous. Id. A finding is clearly erroneous when, although there is evidence to

support it, the reviewing court on the entire evidence is left with a definite and firm

conviction that a mistake has been made. Id. The goal of Arkansas Code Annotated section

9-27-341 is to provide permanency in a minor child’s life in circumstances in which

returning the child to the family home is contrary to the minor’s health, safety, or welfare,

and the evidence demonstrates that a return to the home cannot be accomplished in a

reasonable period of time as viewed from the minor child’s perspective. Id.; Ark. Code Ann.

§ 9-27-341(a)(3) (Repl. 2015). Parental rights may be terminated if clear and convincing

evidence shows (1) that it is in the child’s best interest, and (2) that statutory grounds have

been proved. Hune, supra.

2 Cite as 2016 Ark. App. 368

Here, Hailey and her husband, Kelby, were arrested on June 25, 2015. They had

attempted to use a forged prescription to obtain drugs and were fleeing from a pharmacy

when they were arrested. They were also under the influence of drugs. The Arkansas

Department of Human Services (DHS) exercised a seventy-two-hour hold on D.K., who

was eleven months old at the time. At the time of these events, Hailey and Kelby were

homeless. The probable-cause hearing was held on June 30, 2015; Hailey did not appear at

the hearing; and the trial court found probable cause to remove D.K. from the parents’

custody.

D.K. was adjudicated dependent-neglected following a hearing on September 22,

2015, when the trial court found neglect and parental unfitness. The case goal was set as

reunification, and a case plan was established. DHS filed a petition for termination on

October 9, 2015. The petition alleged several grounds, including aggravated circumstances

based on assertions Hailey and Kelby had previously lost custody of another child in

Oklahoma, and they had made no efforts to adhere to the case plan in the four months since

D.K. had been out of their custody.

The termination hearing was held on December 22, 2015, approximately six months

after the case began. DHS presented evidence Hailey had not addressed her drug problems,

had not obtained stable housing, income, or transportation, and had attended only seven

visits with D.K., which were not meaningful. Hailey did not dispute most of the evidence,

other than to testify that she was living with her father-in-law and Kelby in Oklahoma,

earning $600 a month for taking care of her father-in-law. She acknowledged, however,

that the meth lab resulting in her loss of custody of another child had been located in her

3 Cite as 2016 Ark. App. 368

father-in-law’s house. She also acknowledged not visiting with D.K. because of continued

drug use and lack of housing and transportation.

The paternal grandmother testified she wanted to adopt D.K.; that she had raised

D.K.’s brother, K.K., from the time Oklahoma officials had removed him from Hailey and

Kelby when he was five months old; and that she did not believe Hailey and her son, Kelby,

had made any progress in their stability.

Following the hearing, the trial court granted the petition to terminate, explaining

Hailey had been addicted to drugs for almost half her life, she continued to live with Kelby

(who wasn’t even trying to prevent termination of their parental rights), and both Hailey

and Kelby continued to have issues with drugs that they had not made any effort to correct.

The termination order from which Hailey brought this appeal found two grounds for

termination had been established with clear and convincing evidence: 1) that Hailey had

subjected D.K. to “aggravated circumstances, namely that there is little likelihood that

service to the family will result in reunification”; and 2) that “other factors or issues arose

subsequent to the filing of the original petition for dependency-neglect that demonstrate

that placement of the juvenile in the custody of the parents is contrary to the juvenile’s

health, safety or welfare and that despite the offer of appropriate family services, the parents

has/have manifested the incapacity or indifference to remedy the subsequent issues or factors

or rehabilitate the parents’ circumstances which prevent the placement of the juvenile in

the custody of the parents.” In addition, the trial court concluded termination of Hailey’s

parental rights was in D.K.’s best interest, finding D.K. was adoptable, and D.K. would be

at risk of potential harm if she were returned to Hailey.

4 Cite as 2016 Ark. App. 368

The ultimate adverse ruling was the termination itself. Counsel explains why

challenging the termination would not provide a meritorious basis for reversal. We agree.

One ground is sufficient to support the termination of parental rights. Geatches v.

Arkansas Dep’t of Human Servs., 2016 Ark. App. 344, ____ S.W.3d ____. The trial court

found DHS had established two statutory grounds. One of the grounds found by the trial

court was that Hailey had subjected D.K. to aggravated circumstances. Aggravated

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Related

Canada v. Arkansas Department of Human Services
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2016 Ark. App. 480 (Court of Appeals of Arkansas, 2016)

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2016 Ark. App. 368, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-ark-dept-of-human-servs-arkctapp-2016.