Lylyn Mitchell v. Arkansas Department of Human Services

2021 Ark. App. 162, 622 S.W.3d 644
CourtCourt of Appeals of Arkansas
DecidedApril 14, 2021
StatusPublished
Cited by3 cases

This text of 2021 Ark. App. 162 (Lylyn Mitchell v. Arkansas Department of Human Services) 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
Lylyn Mitchell v. Arkansas Department of Human Services, 2021 Ark. App. 162, 622 S.W.3d 644 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 162 Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and DIVISION II integrity of this document No. CV-20-302 2023.06.26 15:20:23 -05'00' 2023.001.20174 Opinion Delivered April 14, 2021 LYLYN MITCHELL APPELLANT APPEAL FROM THE SEVIER COUNTY CIRCUIT COURT V. [NO. 67CV-18-106]

ARKANSAS DEPARTMENT OF HONORABLE TOM COOPER, HUMAN SERVICES JUDGE APPELLEE AFFIRMED

N. MARK KLAPPENBACH, Judge

An administrative law judge (ALJ) with the Arkansas Department of Human Services

(DHS) determined that Lylyn Mitchell’s name shall be listed on the Arkansas Child

Maltreatment Central Registry. The Sevier County Circuit Court affirmed the ALJ’s

determination. Mitchell now appeals and argues that substantial evidence does not support

the findings of abuse. We affirm.

This case began with allegations that Mitchell’s husband, Daryl, had abused their

foster child, SS, in public. An investigation was initiated by Jessica Bragg of the Crimes

Against Children Division of the Arkansas State Police (CACD). Bragg conducted

interviews with Mitchell, Daryl, their eight-year-old son EM, and two foster children who

had been placed in their home for approximately eight months—four-year-old SS and three-year-old RS. 1 The investigation resulted in multiple true findings of child

maltreatment against Mitchell and Daryl, who both requested an appeal. A hearing was held

before an ALJ with DHS’s Office of Appeals and Hearings to determine whether a

preponderance of the evidence supported findings that the allegations of child maltreatment

were true. Bragg, Mitchell, Daryl, and others testified at the hearing. The ALJ also stated

that she would listen to the recordings of the interviews before making her decision. The

ALJ ultimately found that three allegations against Mitchell were supported by a

preponderance of the evidence and that Mitchell’s name shall be listed on the Arkansas

Child Maltreatment Central Registry. Mitchell petitioned for review in the Sevier County

Circuit Court. The parties filed briefs and made arguments in the circuit court, which

affirmed the order of the ALJ.

Our review is limited in scope and is directed not to the decision of the circuit court

but rather to the decision of the administrative agency. Smith v. Ark. Dep’t of Human Servs.,

2018 Ark. App. 438, 559 S.W.3d 291. It is not the role of the circuit court or an appellate

court to conduct a de novo review of the record; rather, review is limited to ascertaining

whether there is substantial evidence to support the agency’s decision. Id.

Substantial evidence is defined as valid, legal, and persuasive evidence that a

reasonable mind might accept as adequate to support a conclusion and forces the mind to

pass beyond conjecture. Id. To establish an absence of substantial evidence, the challenging

party must demonstrate that the proof before the administrative agency was so nearly

undisputed that fair-minded persons could not reach its conclusion. Id. The question is not

1 Due to his young age, RS did not answer questions and was merely observed.

2 whether the testimony would have supported a contrary finding but whether it supports the

finding that was made. Id.

The Arkansas Administrative Procedure Act (APA) provides that a reviewing court

may reverse or modify the agency’s decision if it concludes that the substantial rights of the

petitioner have been prejudiced because the administrative findings, inferences, conclusions,

or decisions are (1) in violation of constitutional or statutory provisions, (2) in excess of the

agency’s statutory authority, (3) made upon unlawful procedure, (4) affected by other error

or law, (5) not supported by substantial evidence of record, or (6) arbitrary, capricious, or

characterized by abuse of discretion. Ark. Code Ann. § 25-15-212(h) (Supp. 2019).

This court has previously noted that administrative agencies are better equipped than

courts, by specialization, insight through experience, and more flexible procedures, to

determine and analyze underlying legal issues affecting their agencies. Smith, supra. This

recognition accounts for the limited scope of judicial review and the refusal of an appellate

court to substitute its judgment and discretion for that of the administrative agency. Id.

Thus, in making the substantial-evidence determination, we review the entire record and

give the evidence its strongest probative force in favor of the agency’s ruling. Id. Between

two fairly conflicting views, even if the reviewing court might have made a different choice,

the agency’s decision must not be displaced. Id.

Arkansas Code Annotated section 12-18-103 (Supp. 2019) provides definitions of

abuse under the Child Maltreatment Act, which include acts or omissions by a foster parent.

Ark. Code Ann. § 12-18-103(3)(A). The ALJ found that Mitchell had committed abuse

under two definitions. First, the ALJ found that Mitchell’s actions had resulted in a

3 “nonaccidental physical injury” to RS. See Ark. Code Ann. § 12-18-103(3)(A)(v). The ALJ

found that Mitchell admitted hitting the children with a ruler as a form of discipline, and

she found that it was more likely than not that blunt, linear bruising on RS’s back and leg

was caused by the ruler and was a result of Mitchell’s actions. The ALJ also attributed a

bruise on EM’s leg to Mitchell’s use of the ruler, but the ALJ found that EM’s injury was

excluded from the definition of abuse under the physical-discipline exception. The ALJ

found that the physical-discipline exception was not applicable to RS’s injuries because

Mitchell was not RS’s parent or guardian.

The ALJ also found that Mitchell had committed abuse by intentionally or knowingly

striking a child six years of age or younger on the face or head with or without physical

injury. See Ark. Code Ann. § 12-18-103(3)(A)(vii)(a). This finding was made regarding both

SS and RS. The ALJ found that Mitchell had admitted in her recorded interview that she

would “bop” the children on the head with a ruler when they misbehaved. Mitchell stated

that although she was aware that it is against DHS policy to administer corporal punishment

to foster children, she elected to disregard the rules, and she stated that she used the ruler as

an aide in disciplining the children due to her petite stature. The ALJ found that EM and

SS had credibly disclosed in their interviews that Mitchell had hit them and RS on the head

with the ruler on more than one occasion. 2 The ALJ noted that Mitchell attempted to justify

her actions by stating that she only “bopped” the children on their heads and did not rear

2 Although the ALJ found that Mitchell would intentionally strike EM on the head, this act was not found to be abuse because EM was over the age of six and there was insufficient evidence that he had ever sustained an injury from this act as required under Arkansas Code Annotated section 12-18-103(3)(A)(vi)(d).

4 back and strike them hard; however, the ALJ found that using the ruler on the children’s

heads as a planned form of discipline was not justified by the excuse that the actions were

not “hard.” The ALJ found that the purpose of corporal discipline is to inflict some degree

of pain to a child in an effort to modify the child’s misbehavior.

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2021 Ark. App. 162, 622 S.W.3d 644, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lylyn-mitchell-v-arkansas-department-of-human-services-arkctapp-2021.