State Ex Rel. CYFD v. James M.

CourtNew Mexico Court of Appeals
DecidedSeptember 26, 2022
StatusUnpublished

This text of State Ex Rel. CYFD v. James M. (State Ex Rel. CYFD v. James M.) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Ex Rel. CYFD v. James M., (N.M. Ct. App. 2022).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion. 1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: ______________

3 Filing Date: September 26, 2022

4 No. A-1-CA-39480

5 STATE OF NEW MEXICO ex rel. 6 CHILDREN, YOUTH & FAMILIES 7 DEPARTMENT,

8 Petitioner-Appellee,

9 v.

10 JAMES M.,

11 Respondent-Appellant,

12 and

13 FARRAH S.,

14 Respondent,

15 IN THE MATTER OF JOVAN M., 16 JAMIA M., and JARROM M.,

17 Children.

18 APPEAL FROM THE DISTRICT COURT OF SAN MIGUEL COUNTY 19 Flora Gallegos, District Judge 1 Children, Youth & Families Department 2 Mary McQueeney, Chief Children’s Court Attorney 3 Santa Fe, NM 4 Kelly P. O’Neill, Assistant Children’s Court Attorney 5 Albuquerque, NM

6 for Appellee

7 Susan C. Baker 8 El Prado, NM

9 for Appellant

10 Victoria W. Doom 11 Las Vegas, NM

12 Guardian Ad Litem 1 OPINION

2 YOHALEM, Judge.

3 {1} James M. (Father) appeals the district court’s order terminating his parental

4 rights to his three children (Children). 1 This case is subject to the Indian Child

5 Welfare Act of 1978 (ICWA), 25 U.S.C. §§ 1901 to 1963. ICWA sets “minimum

6 Federal standards” for the removal of an Indian child from their family, for continued

7 state custody of an Indian child, and, most relevant here, for the termination of

8 parental rights to an Indian child. 25 U.S.C. § 1902.

9 {2} Father raises two issues on appeal, which he contends require reversal of the

10 district court’s judgment terminating his parental rights. First, Father contends that

11 ICWA and New Mexico state law require the district court at the adjudicatory

12 hearing to find that Father abused or neglected Children by evidence beyond a

13 reasonable doubt, rather than by clear and convincing evidence. We conclude that

14 ICWA and New Mexico law together require that a district court’s findings of abuse

15 and neglect at an adjudication involving an Indian child be supported by clear and

16 convincing evidence, not evidence beyond a reasonable doubt. We, therefore, find

17 no error in the district court’s findings at adjudication. 2

1 The parental rights of Farrah S. (Mother) were terminated in the same proceeding. Mother has not appealed. 2 We note that the New Mexico Legislature adopted a new statute governing abuse and neglect and custody proceedings concerning Indian children in 2022: the Indian Child Protection Act (ICPA), NMSA 1978, §§ 32A-28-1 to -42 (2022). This 1 {3} Father next contends that the district court’s finding pursuant to ICWA, 25

2 U.S.C. § 1912(d), that the Children, Youth & Families Department (CYFD) made

3 “active efforts” to reunite Father and Children and prevent the breakup of the Indian

4 family was not supported by sufficient evidence at the termination of parental rights

5 (TPR) hearing. We agree with Father that CYFD failed to present evidence sufficient

6 to support the district court’s finding beyond a reasonable doubt that the efforts

7 CYFD made to assist Father complied with the “active efforts” requirement of

8 ICWA. We reverse and remand on this basis for proceedings consistent with this

9 opinion.

10 BACKGROUND

11 {4} We briefly review the circumstances leading to Children being taken into

12 custody by CYFD, the facts supporting the adjudication of neglect by Father, and

13 Father’s treatment plan.

14 {5} Children were in the care of Mother when the abuse and neglect petition was

15 filed on February 14, 2019. Father was living in Louisiana and working as a long-

16 haul truck driver. Mother had previously been involved with Zuni Pueblo’s social

case was filed in 2018; therefore, we rely on the provisions of the New Mexico Abuse and Neglect Act (ANA), NMSA 1978, §§ 32A-4-1 to -35 (1993, as amended through 2022), as well as ICWA, which were in place before the adoption of ICPA. We note that there is no significant difference relevant to the issues discussed in this opinion between the federal and state law applied in this opinion and ICPA.

2 1 services agency due to substance abuse resulting in neglect of Children. She did not

2 successfully work her treatment plan.

3 {6} The two older Children had lived with Father from March 2018 until he

4 returned them to Mother eight months later in November 2018. Father testified at

5 the TPR hearing that he returned them, in part, because he believed Mother had

6 stopped using drugs and was doing better. Father knew that a tribal judge had

7 returned Mother’s other two children to her in June or July 2018, supporting his

8 belief that Mother was doing better. He hoped at that time to have an ongoing

9 relationship with her.

10 {7} Father testified at the TPR hearing that when he visited in November, he had

11 some concerns but did not see obvious signs that Mother was using drugs. Later,

12 when he called Mother, she started hanging up on him and sounded strange. Father

13 called the police to ask them to do a welfare check on Children. When he did not

14 hear anything about the welfare check, Father made a trip to New Mexico to check

15 on Children. Finding that Mother was drinking, he called CYFD. Although he

16 believed Mother’s behavior put Children at risk, he left Children with her and

17 returned to his home and job in Louisiana.

18 {8} In mid-February 2019 Father learned from Mother that Children had been

19 taken into state custody. Father contacted CYFD the next day. At the adjudicatory

20 hearing, Father testified that he did not have the ability to care for Children

3 1 immediately. He said he was looking for a new job that would allow him to work

2 locally so he could be home with Children. A CYFD investigator testified at the

3 adjudicatory hearing that Father had been able to obtain low-cost housing when

4 Children were living with him, but no longer qualified when he was living on his

5 own. The investigator reported that Father did not have appropriate housing to take

6 care of Children at the time of the adjudication. The district court found, by clear

7 and convincing evidence, that Father had neglected Children, pursuant to Section

8 32A-4-2(G)(2) (defining a “neglected child” to mean a parent’s inability to provide

9 adequate care because of the parent’s faults or habits), and found as well, also by

10 clear and convincing evidence, that continued custody of Children by Father was

11 “likely to result in serious emotional or physical damage” to Children, a finding

12 required by ICWA, 25 U.S.C. § 1912(e), because he had placed Children at risk by

13 leaving them with Mother, knowing Mother was drinking and using drugs.

14 {9} The district court’s findings state that the court was not persuaded that

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Bluebook (online)
State Ex Rel. CYFD v. James M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-cyfd-v-james-m-nmctapp-2022.