Reco Smith v. Arkansas Department of Human Services and Minor Child

2025 Ark. App. 325
CourtCourt of Appeals of Arkansas
DecidedMay 21, 2025
StatusPublished

This text of 2025 Ark. App. 325 (Reco Smith v. Arkansas Department of Human Services and Minor Child) 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
Reco Smith v. Arkansas Department of Human Services and Minor Child, 2025 Ark. App. 325 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 325 ARKANSAS COURT OF APPEALS DIVISION I No. CV-25-62

Opinion Delivered May 21, 2025 RECO SMITH APPELLANT APPEAL FROM THE POINSETT COUNTY CIRCUIT COURT V. [NO. 56JV-23-124]

ARKANSAS DEPARTMENT OF HONORABLE CHARLES M. HUMAN SERVICES AND MINOR MOONEY, JR., JUDGE CHILD AFFIRMED APPELLEES

MIKE MURPHY, Judge

Appellant Reco Smith appeals from the Poinsett County Circuit Court’s termination

of his parental rights to Minor Child (MC), born August 26, 2022. 1 On appeal, he argues

sufficient evidence did not support the termination of his parental rights, challenging the

circuit court’s best-interest finding. We affirm.

The Arkansas Department of Human Services (DHS) has a history with this family.

Most recently on July 19, 2023, DHS filed a petition for emergency custody and dependency-

neglect of eleven-month-old MC alleging that she was dependent-neglected as a result of

abuse, neglect, or parental unfitness. The circuit court signed an ex parte order for emergency

1 Madison Biddle is MC’s biological mother whose rights were also terminated. She is not a party to this appeal. custody the same day. A probable-cause hearing was held on July 25. Smith had not yet been

served. His demographic information was unknown to DHS at the time of removal because

the biological mother was not cooperative in providing the information. The mother

stipulated to and the court found probable cause for DHS to take emergency custody of MC

and that probable cause continued to exist such that it was necessary and in the best interest

of MC to remain in the custody of DHS. MC was adjudicated dependent-neglected on

August 29 on the grounds of parental unfitness due to the mother’s drug use.

A review hearing was held on December 5, 2023. Smith appeared via Zoom. DHS

was found to have made reasonable efforts to provide family services and finalize a

permanency plan for MC. Smith was found to be noncompliant with the case plan because

he had been incarcerated throughout the case and unable to participate in services. DHS was

ordered to assist in DNA testing to establish his paternity.

A permanency-planning hearing was held on July 16, 2024. Smith was found to be

noncompliant with the case plan since he was still incarcerated and had been incarcerated

since the beginning of the case. The goal of the case was changed to adoption following

termination of parental rights with a concurrent goal of relative custody. DHS was ordered

to investigate relatives identified by Smith at the hearing for possible placement.

On July 19, DHS filed a petition for termination of parental rights. A hearing was

conducted on October 15. At the outset, the court entered an order declaring Smith to be

the legal father of MC and establishing his paternity. DHS introduced three exhibits without

objection, including two sentencing orders in criminal proceedings involving Smith.

2 Pertinent to the issue on appeal, testimony established the following. MC was now

two years old and thriving in her foster placement. She is adoptable, and the foster family

was interested in adopting her. DHS was unable to provide many rehabilitative services to

Smith because of his incarceration. Smith was arrested on July 17, 2023, and had been

incarcerated ever since. He was convicted of breaking or entering, a Class D felony, on

August 31, 2022, and sentenced to a period of seventy-two months’ probation. He was

convicted of robbery, a Class B felony, on November 27, 2023, and sentenced to a period of

thirty-six months’ incarceration. He had not seen MC in more than twelve months, and he

was uncertain MC was his child until the DNA test. Before his arrest, he was homeless and

did not have stable employment.

As ordered, DHS investigated Smith’s relatives for possible placement. Smith’s

mother, Lola Johnson Smith, was considered in April 2024 but was initially denied because

she lived in a senior housing facility that did not allow children, she had a true finding on

her record, and she did not have reliable transportation. She relied on the Medicaid van to

transport her to appointments. Lola was provided with information on what she would need

to correct to be reconsidered, and she had not fully made those corrections. The most

significant thing she had left to do was secure appropriate housing. Lola was provided with

a paper to complete and return to HUD, and as of the termination hearing, she had not

returned it. Lola had never met MC, and according to DHS, she often could not recall MC’s

name.

3 Lola testified and acknowledged that she was living in a senior facility that did not

allow children. She said she did not get the paperwork concerning assistance in housing that

allows children until about a month before the hearing. She is diabetic and received a letter

from her doctor saying she could take care of MC. Lola cared for her other grandchildren,

and they occasionally stayed the night. She has several grandchildren, the youngest being

several months old. Lola testified that she relies on her sons for transportation.

Mario Smith, a paternal uncle, was considered but not recommended. Before DHS

submits a packet on a person to be considered for placement, it runs a search in its system

and in CourtConnect. The search on Mario revealed that he had three prior true findings

for sexual contact with a minor when he was sixteen years old. Mario also had three criminal

convictions: a DWI from 2022; a charge for filing a false police report, careless and

prohibited driving, and leaving the scene of an accident in 2021; and a theft-of-property

charge in 2015. DHS did not believe Mario was an appropriate placement, so they did not

submit a packet for further review.

Mario testified that he and his wife live alone. The children he helped raise are grown

and out of the home. He has one minor child who is fourteen years old who lives out of state

with her mother. He has grandchildren who stay with them on the weekends. His home has

plenty of space and he has a stable job. Mario testified he and his wife have enough income

to provide for MC. He testified that about three to four months before the hearing, he

reached out to DHS about his desire to be considered as a placement for MC, but he had

not followed up. He was not aware of the true findings against him because he thought an

4 investigation determined he was not responsible, and the charges were dropped. Mario

acknowledged his criminal history pertaining to a hot check and two DWIs.

Anthony Smith, a paternal uncle, was also considered but not recommended. DHS’s

preliminary search found a true finding from 2009 for sexual penetration with a minor and

a true finding from 2019 for a subdural hematoma and a bone fracture pertaining to one of

his own children. Neither of the uncles had an established relationship with MC. Anthony

did not testify.

At the conclusion of the hearing, the circuit court ruled that it was granting the

petition and terminating Smith’s parental rights to his child. Specifically, the circuit court

terminated Smith’s parental rights on three grounds: his failure to maintain contact or

provide support, his substantial sentence in a criminal proceeding, and a finding of

aggravated circumstances. The written order was entered November 18, and Smith filed a

timely notice of appeal.

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2025 Ark. App. 325, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reco-smith-v-arkansas-department-of-human-services-and-minor-child-arkctapp-2025.