State ex rel. W.M.O.

905 So. 2d 1164, 2004 La.App. 4 Cir. 2025, 2005 La. App. LEXIS 1584, 2005 WL 1399089
CourtLouisiana Court of Appeal
DecidedJune 1, 2005
DocketNo. 2004-CA-2025
StatusPublished
Cited by2 cases

This text of 905 So. 2d 1164 (State ex rel. W.M.O.) 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. W.M.O., 905 So. 2d 1164, 2004 La.App. 4 Cir. 2025, 2005 La. App. LEXIS 1584, 2005 WL 1399089 (La. Ct. App. 2005).

Opinions

LOMBARD, J.

RELEVANT FACTS AND PROCEDURAL HISTORY

E.O., mother of R.M.O. and W.M.O., has received services from the Department of Social Services Office of Community Services (“DSS/OCS”) since 1993. W.M.O., twelve years old, and R.M.O., ten years old, entered foster care on August 19, 1999, and have remained in foster care ever since. Their thirteen-year-old brother, S.M.O., entered foster care with them, but is not part of this proceeding. On October 7, 1999, they were adjudicated to be “children in need of care” and the court approved a case plan for the safe return of the children to their family.

W.M.O. has been diagnosed with pervasive development disorder, disruptive behavior disorder, post-traumatic stress syndrome, and moderate mental retardation. A neighbor sexually abused W.M.O. when he lived with his mother, and W.M.O. sexually abused R.M.O. when they were placed together in foster care. R.M.O. has been diagnosed with bipolar disorder, attention deficit disorder, and nocturnal enuresis, having experienced previous neglect and sexual abuse. Some of these illnesses are lifelong conditions, but all are treatable with [^medication and therapy. The boys require continuous, direct supervision and support by an adult at all times.

Reunification of W.M.O. and R.M.O. with E.O. was attempted by starting with over-night visitation. During the reunification, the children were exposed to sexually inappropriate behavior by the mother and domestic violence between the mother and her boyfriend.

On September 29, 2004, the Orleans Parish Juvenile Court ruled that the State, through the Department of Social Services, Office of Community Services (“DSS/OCS”), proved the elements for a termination of parental rights required by Children’s Code Art. 1015 and proved that the children cannot be returned to the mother. The juvenile court also found that there was proof of grounds to terminate the father’s parental rights. The court found that, while the State proved the grounds for the termination of parental rights, the State did not prove that termination was in the children’s best interest.

The State filed an appeal as to the denial of the termination based on the best interest issue only. The mother, E.O., has appealed the finding that the grounds for termination were proven. The father did not appeal.

LAW AND DISCUSSION

An appellate court cannot set aside a juvenile court’s findings of fact in the absence of manifest error or unless those findings are clearly wrong. In re A.J.F., 00-0948, p. 25 (La.6/30/00), 764 So.2d 47, 61.

LSA-Ch.C. art. 1015 provides the grounds for which parental rights may be terminated. LSA-Ch.C. art. 1015(5) provides:

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 |3court order; there has been no substantial parental compliance with a 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 im[1167]*1167provement 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.

In this case, it is undisputed that more than one year has elapsed since R.M.O. and W.M.O. were removed from E.O.’s custody pursuant to a court order. The record reveals that the children were placed in foster care on August 19, 1999, and DSS/OCS filed its petition to terminate the parents’ parental rights on May 25, 2004. The State contends that it has met its burden of proving that E.O. has not substantially complied with the case plan, and there is no reasonable expectation of improvement of E.O.’s condition and/or conduct.

In order to terminate rights, the court must find that the State has established at least one of the statutory grounds contained in LSA-Ch.C. art. 1015 by clear and convincing evidence. State in the Interest of J.A., 99-2905, p. 8 (La. 1/12/00), 752 So.2d 806, 811. Further, even upon finding that the State has met its eviden-tiary burden, a court still should not terminate parental rights unless it determines that to do so is in the child’s best interest. LSA-Ch.C. art. 1037(A); State in the Interest of C.J.K., 00-2375, p. 8 (La.11/28/00), 774 So.2d 107, 113.

LSA-Ch.C. art. 1036(C) enumerates the substantive elements proving lack of substantial compliance with a court-approved case plan. This prong may be evidenced by one or more of the following:

|4(1) The parent’s failure to attend court-approved scheduled visitations with the child.
(2) The parent’s failure to communicate with the child.
(3) The parent’s failure to keep the department apprised of the parent’s whereabouts and significant changes affecting the parent’s ability to comply with the case plan for services.
(4) The parent’s failure to contribute to the costs of the child’s foster care, if ordered to do so by the court when approving the case plan.
(5) The parent’s repeated failure to comply with the required program of treatment and rehabilitation services provided in the case plan.
(6) The parent’s lack of substantial improvement in redressing the problems preventing reunification.

Likewise, the substantive elements proving lack of a reasonable expectation of significant improvement in the near future are set forth in LSA-Ch.C. art. 1036(D), which provides that this prong may be shown by one or more of the following:

(1) Any physical or mental illness, mental deficiency, substance abuse or chemical dependency that renders the parent unable or incapable of exercising parental responsibilities without exposing the child to a substantial risk of serious harm, based upon expert opinion or based upon an established pattern of behavior.
(2) A pattern of repeated incarceration of the parent that has rendered the parent unable to care for the immediate and continuing physical or emotional needs of the child for extended periods of time.
(3) Any other condition or conduct that reasonably indicates that the parent is unable or unwilling to provide an adequate permanent home for the child, based upon expert opinion or based upon an established pattern of behavior.

The primary concern of the courts and the State remains to determine and ensure the best interest of the child, which includes termination of parental rights if justifiable statutory grounds exist and are proven by the State. State in the Interest [1168]*1168of S.M.W., 00-3277, p. 21 (La.2/21/01), 781 So.2d 1223, 1238.

Applying the aforementioned law to this case, we must determine (1) whether the State has established the grounds for termination set forth in LSA-Ch.C. art. 1015(5) by clear and convincing evidence; and, (2) whether, it is in |BR.M.O.’s and W.M.O.’s best interest to terminate E.O.’s parental rights.

Under E.O.’s case plan, she was to have evaluations, complete parenting classes, go to therapy, and participate in the children’s therapy. E.O.

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Bluebook (online)
905 So. 2d 1164, 2004 La.App. 4 Cir. 2025, 2005 La. App. LEXIS 1584, 2005 WL 1399089, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-wmo-lactapp-2005.