State ex rel. C.L.H.

66 So. 3d 647, 11 La.App. 3 Cir. 189, 2011 La. App. LEXIS 689
CourtLouisiana Court of Appeal
DecidedJune 1, 2011
DocketNo. 11-189
StatusPublished
Cited by2 cases

This text of 66 So. 3d 647 (State ex rel. C.L.H.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. C.L.H., 66 So. 3d 647, 11 La.App. 3 Cir. 189, 2011 La. App. LEXIS 689 (La. Ct. App. 2011).

Opinion

GENOVESE, Judge.

The State of Louisiana, through its Department of Social Services, Office of Community Services, renamed Department of Children and Family Services (State), appeals the judgment of the trial court dismissing its petition to terminate the biological mother’s parental rights. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL HISTORY

On July 15, 2010, the State filed a Petition for Certification for Adoption and Termination of Parental Rights of L.A.H.,1 the biological mother of C.L.H. (date of birth April 21, 2003), T.L.E. (date of birth December 13, 2005), and T.A.H. (date of birth May 20, 2008). The State asserted that two of the children, C.L.H. and T.L.E., were taken into the State’s custody on January 26, 2009, and that T.A.H. was taken into the State’s custody on February [649]*6491, 2009, after L.A.H. was “arrested for various drug[-]related criminal charges when [her] house was raided by the Sul-phur Police Department.” According to the State’s petition, the three children were returned to L.A.H. on a trial basis on October 5, 2009; however, on October 23, 2009, the temporary placement ceased, and the children were again placed into foster care. The State sought to have L.A.H.’s parental rights terminated pursuant La. Ch.Code art. 1015(4), La.Ch.Code art. 1015(5), and La.Ch.Code art. 1036.

In its petition, the State asserted that L.A.H. had not substantially complied with her case plan. Specifically, the State alleged that L.A.H.: (1) had “not obtained safe, stable housing[;]” (2) had “not provided any proof of legal income[;]” (3) had not satisfactorily completed outpatient treatment with the Office of Addictive Disorders; (4) had failed a random drug screen in December of 2009 and was arrested for possession and distribution of marijuana in February of 2010; (5) had attended the 12incorrect parenting course and had yet to attend the parenting course the State deemed acceptable; (6) had attended a course for domestic abuse victims but needed to attend another course since the State alleged that L.A.H. had “returned to being around drug users and dealers[;]” and (7) had “failed to make any monthly contributions toward the care of her children.” The State did concede, however, that L.A.H. was in compliance with her case plan’s requirement that she regularly visit her three children.

On October 21, 2010, a termination hearing was held. Following said hearing, the trial court dismissed the State’s petition against L.A.H.,2 finding that she had substantially complied with her case plan. The State appeals.

ASSIGNMENTS OF ERROR

On appeal, the State asserts:

The trial court committed manifest error by finding that the mother was in substantial compliance with her case plan, that there was reasonable expectation of significant improvement in the mother’s condition, by failing to find that the State had proven that the mother’s parental rights should be terminated based upon Children’s Code Article 1015(4) and (5) and Article 1036, and failing to find that it was in the best interest of the children that the mother’s parental rights be terminated.
Additionally, the trial court committed manifest error by applying the incorrect burden of proof and requiring the mother be convicted of criminal charges before he would hold the two (2) drug busts against her.

LAW AND DISCUSSION

Louisiana Children’s Code Article 1035 requires that the State establish “each element of a ground for termination of parental rights by clear and convincing evidence.” This court, in State in the Interest of M.R. v. S.F.H., 09-889, pp. 2-3 (La.App. 3 Cir. 12/9/09), 25 So.3d 1021, 1022-23, writ denied, 09-2812 (La.1/14/10), 24 So.3d 878, set forth both the burden of proof which the State must meet and the standard of appellate review in parental termination matters as follows:

The termination of parental rights is a two-pronged inquiry. First, the State must prove by clear and convincing evidence the existence of, at least, one [650]*650ground for termination under La.Ch. Code art. 1015. La.Ch.Code art. 1035(A); Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982). Only after the ground for termination is found, the trial court must determine whether the termination is within the best interest of the child. La.Ch.Code art. 1039. On review of a termination of parental rights, an appellate court cannot set aside a trial court’s finding of fact in the absence of manifest error or unless the findings are clearly wrong. State in the Interest of KG. & T.G., 02-2886, 02-2892 (La.3/18/03), 841 So.2d 759.

Thus, the State must first establish by clear and convincing evidence one of the statutory grounds for involuntary termination of a parent’s rights, and then the State must establish by clear and convincing evidence that termination of parental rights is in the child’s best interest. Id.

In the present case, the State’s Petition for Certification for Adoption and Termination of Parental Rights alleged that termination of L.A.H.’s parental rights was appropriate pursuant to La.Ch.Code art. 1015(4), La.Ch.Code art. 1015(5), and La. Ch.Code art. 1036.3 The relevant subsections of La.Ch.Code art. 1015 include the | ¿following grounds for termination:

(4) Abandonment of the child by placing him in the physical custody of a nonparent, or the department, or by otherwise leaving him under circumstances demonstrating an intention to perma[651]*651nently avoid parental responsibility by any of the following:
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(b) As of the time the petition is filed, the parent has failed to provide significant contributions to the child’s care and support for any period of six consecutive months.
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(5) Unless sooner permitted by the court, at least one year has elapsed since a child was removed from the parent’s custody pursuant to a court order; there has been no substantial parental compliance with |sa case plan for services which has been previously filed by the department and approved by the court as necessary for the safe return of the child; and despite earlier intervention, there is no reasonable expectation of significant improvement in the parent’s condition or conduct in the near future, considering the child’s age and his need for a safe, stable, and permanent home.

The trial court found that the State had not established by clear and convincing evidence the grounds for terminating L.A.H.’s parental rights. We hold that the trial court did not clearly err in finding that the State failed to prove either ground by clear and convincing evidence.

At the October 21, 2010 trial, the State first called L.A.H. to testify. When questioned about whether she had complied with her case plan’s requirement that she obtain employment, L.A.H. testified that to comply with her case plan, she worked at her brother-in-law’s construction company until October of 2009. According to L.A.H., she stopped working during the time that her children were returned to her because she did not have a babysitter. After her children were again placed into foster care, L.A.H.

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State ex rel. R.E.
91 So. 3d 1282 (Louisiana Court of Appeal, 2012)
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Bluebook (online)
66 So. 3d 647, 11 La.App. 3 Cir. 189, 2011 La. App. LEXIS 689, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-clh-lactapp-2011.