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

2017 Ark. App. 495
CourtCourt of Appeals of Arkansas
DecidedOctober 4, 2017
DocketCV-17-251
StatusPublished
Cited by7 cases

This text of 2017 Ark. App. 495 (Mercado 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
Mercado v. Ark. Dep't of Human Servs., 2017 Ark. App. 495 (Ark. Ct. App. 2017).

Opinion

Cite as 2017 Ark. App. 495

ARKANSAS COURT OF APPEALS DIVISION III CV-17-251 No.

FRANCESCA MERCADO Opinion Delivered: October 4, 2017 APPELLANT APPEAL FROM THE SEBASTIAN V. COUNTY CIRCUIT COURT, FORT SMITH DISTRICT ARKANSAS DEPARTMENT OF HUMAN [NO. 66FJV-16-284] SERVICES AND MINOR CHILD APPELLEES HONORABLE JIM D. SPEARS, JUDGE

AFFFIRMED; MOTION GRANTED

RITA W. GRUBER, Chief Judge

Counsel for Francesca Mercado brings this no-merit appeal from the circuit court’s

December 28, 2016 order terminating Mercado’s parental rights to A.M., who was born on

February 27, 2016. Pursuant to Linker-Flores v. Arkansas Department of Human Services, 359

Ark. 131, 194 S.W.3d 739 (2004), and Arkansas Supreme Court Rule 6-9(i), counsel has

filed a no-merit brief setting forth all adverse rulings from the termination hearing and

asserting that there are no issues that would support a meritorious appeal. Counsel has also

filed a motion asking to be relieved. Mercado has filed pro se points. The Arkansas

Department of Human Services (DHS) and the minor child’s counsel have responded to

those pro se points. We grant counsel’s motion to withdraw and affirm the termination

order.

Termination of parental rights is a two-step process requiring a determination that

the parent is unfit and that termination is in the best interest of the child. Houseman v. Ark. Cite as 2017 Ark. App. 495

Dep’t of Human Servs., 2016 Ark. App. 227, at 2, 491 S.W.3d 153, 155. The first step requires

proof of one or more statutory grounds for termination; the second step requires

consideration of whether termination is in the juvenile’s best interest. Ark. Code Ann. §

9-27-341(b)(3)(B), (A) (Repl. 2015). Each of these requires proof by clear and convincing

evidence, which is the degree of proof that will produce in the fact-finder a firm conviction

regarding the allegation sought to be established. Id.

We review termination-of-parental-rights cases de novo. Norton v. Ark. Dep’t of

Human Servs., 2017 Ark. App. 285, at 2. Our inquiry is whether the circuit court’s finding

that the disputed fact was proved 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. Houseman, supra. In resolving the clearly erroneous question, the reviewing

court defers to the circuit court’s superior opportunity to observe the parties and to judge

the witnesses’ credibility. Brumley v. Ark. Dep’t of Human Servs., 2015 Ark. 356, at 7.

In Mercado v. Arkansas Department of Human Services, 2017 Ark. App. 232, 519 S.W.3d

715 (Mercado I), we recounted earlier proceedings in this case:

On June 17, 2016, the Arkansas Department of Human Services (DHS) exercised a 72-hour hold on three-month-old A.M. after a medical examination at Arkansas Children’s Hospital revealed bone fractures, head trauma, brain damage, and a subdural hematoma. A probable-cause order was entered on August 17, 2016, continuing custody of A.M. with DHS. The court held a hearing on September 12, 2016, after DHS filed a motion to terminate reunification services. Dr. Karen Farst, a specialist in child-abuse pediatrics who examined A.M. at Children’s, testified at the hearing that A.M.’s head injury was a “near fatality” and that her injuries were “indicative of physical abuse.” Following the hearing, the circuit court adjudicated A.M. dependent-neglected with the stated goal of adoption, and granted DHSs’ motion to terminate reunification services. The court entered a separate order

2 Cite as 2017 Ark. App. 495

denying appellant’s petition for a second medical-expert opinion. The court attached Rule 54(b) certificates to both orders.

Mercado I, 2017 Ark. App. 232, at 1–2, 519 S.W.3d at 715–16. Mercado filed her notice of

appeal in Mercado I from the circuit court’s orders adjudicating A.M. dependent-neglected,

relieving DHS from providing reunification services, and denying Mercado’s petition for a

second medical-expert opinion. However, her sole point on appeal was that the circuit

court erred in denying her petition for a separate medical expert. We affirmed. Id. at 3,

519 S.W.3d at 717.

In the order terminating Mercado’s parental rights, the circuit court found that the

State had proved two statutory grounds. The first ground states, as relevant to the present

case:

(vi) The court has found the juvenile . . . dependent-neglected as a result of neglect or abuse that could endanger the life of the child, . . . which was perpetrated by the juvenile’s parent or parents or stepparent or stepparents. .... (b) Such findings by the juvenile division of circuit court shall constitute grounds for immediate termination of the parental rights of one (1) or both of the parents;

Ark. Code Ann. § 9-27-341(b)(3)(B)(vi)(a) & (b). Under the second ground,

a court of competent jurisdiction has found the parent to have subjected any juvenile to

aggravated circumstances. Ark. Code Ann. § 9-27-341(b)(3)(B)(ix) (Repl. 2015).

“Aggravated circumstances” means, in relevant part, that a juvenile has been “chronically

abused, subjected to extreme or repeated cruelty”; or that a determination has been made

by a judge that “there is little likelihood that services to the family will result in successful

reunification.” Ark. Code Ann. § 9-27-341(b)(3)(B)(ix)(a)(3)(B)(i).

3 Cite as 2017 Ark. App. 495

In termination cases, a challenge to a finding of abuse or aggravated circumstances

must be made, if at all, in an appeal from the adjudication hearing. Hannah v. Ark. Dep’t of

Human Servs., 2013 Ark. App. 502, at 4 (citing Dowdy v. Ark. Dep’t of Human Servs., 2009

Ark. App. 180, 314 S.W.3d 722). Here, the two statutory grounds for termination were

based on previous findings in the adjudication order. Thus, counsel states in the present

no-merit appeal that there can be no challenge to the grounds for termination because they

were not challenged in the appeal of the adjudication order.

Counsel also states that the court’s best-interest finding does not provide a basis for

reversal. The best-interest analysis includes consideration of the likelihood that the juvenile

will be adopted and of the potential harm caused by returning custody of the child to the

parent. Ark. Code Ann. § 9-27-341(b)(3)(A). Counsel concludes that, particularly in light

of our great deference to the circuit court’s superior ability to determine credibility of

witnesses, there was sufficient evidence to support the circuit court’s finding that

termination of Mercado’s parental rights was in A.M.’s best interest. Wafford v. Ark. Dep’t

of Human Servs., 2016 Ark. App. 299, at 5, 495 S.W.3d 96, 100.

In addition to the statutory grounds for termination and the court’s best-interest

analysis, the court made other rulings adverse to Mercado. Counsel’s brief includes a

discussion of each ruling that was preserved for review, along with an explanation of why

reversal is not warranted.

Pro Se Points

Mercado asserts in her pro se points that she did not neglect or abuse A.M. She raises

various arguments: (1) even after DHS had stopped providing services, she (Mercado)

4 Cite as 2017 Ark. App. 495

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Teresa Baird v. Arkansas Department of Human Services and Minor Children
2023 Ark. App. 129 (Court of Appeals of Arkansas, 2023)
Leraye Atwood v. Arkansas Department of Human Services and Minor Children
2022 Ark. App. 230 (Court of Appeals of Arkansas, 2022)
Philip Wallace v. Arkansas Department of Human Services and Minor Children
2020 Ark. App. 67 (Court of Appeals of Arkansas, 2020)
Amber Westbrook v. Arkansas Department of Human Services and Minor Child
2019 Ark. App. 352 (Court of Appeals of Arkansas, 2019)
Rylie v. Ark. Dep't of Human Servs.
554 S.W.3d 275 (Court of Appeals of Arkansas, 2018)
McKinney v. Ark. Dep't of Human Servs. & Minor Children
544 S.W.3d 101 (Court of Appeals of Arkansas, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
2017 Ark. App. 495, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mercado-v-ark-dept-of-human-servs-arkctapp-2017.