State in the Interest of A.N.C.

CourtLouisiana Court of Appeal
DecidedApril 8, 2026
DocketJAC-0025-0676
StatusUnknown

This text of State in the Interest of A.N.C. (State in the Interest of A.N.C.) 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 in the Interest of A.N.C., (La. Ct. App. 2026).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

25-676

STATE IN THE INTEREST OF

A.N.C.

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NUMBER 2024-TP-11 HONORABLE LOREN M. LAMPERT, DISTRICT JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Sharon Darville Wilson, Guy E. Bradberry and Wilbur L. Stiles, Judges.

AFFIRMED. Annette Roach ROACH & ROACH, APLC 2720 Rue de Jardin, Suite 100 Lake Charles, Louisiana 70605 (337) 436-2900 COUNSEL FOR APPELLANTS: M.T.C., Sr. & J.N.C.

Ruby Norris Freeman LOUISIANA DEPARTMENT OF CHILDREN AND FAMILY SERVICES BUREAU OF GENERAL COUNSEL 900 Murray Street Alexandria, Louisiana 71301 (318) 484-2178 COUNSEL FOR APPELLEE: State of Louisiana WILSON, Judge.

J.N.C. and M.T.C. appeal the judgment of the trial court terminating their

parental rights to the minor child A.N.C. and certifying her for adoption. 1 For the

reasons expressed below, we affirm the judgment of the trial court.

I.

ISSUES

On appeal, J.N.C. and M.T.C. assert the following assignments of error:

(1) The court manifestly erred by finding clear and convincing evidence was presented to establish that both J.N.C. or [M.T.C.] had not substantially complied with their case plans, that [the Department of Children and Family Services (DCFS)] provided reasonable efforts to assist both parents to complete their respective case plans, and that there was no reasonable expectation of a significant improvement by either parent in the near future.

(2) The court manifestly erred by finding that the State proved by clear and convincing evidence that termination of the parental rights of either J.N.C. or [M.T.C.] was in the best interes[t] of A.N.C.

J.N.C. and M.T.C. also filed a motion to strike a portion of the exhibits

submitted to the court to the extent that there are references to events that occurred

after the July 31, 2025 hearing as well as documents filed after this date. DCFS filed

an opposition to the motion. The motion to strike was referred to the merits of this

appeal.

1 The initials of the minor child and parents are used to preserve the anonymity in this confidential proceeding. See Uniform Rules—Courts of Appeal, Rules 5–1 and 5–2. II.

FACTS AND PROCEDURAL HISTORY

J.N.C. and M.T.C. are the biological parents of A.N.C., a girl born on May

16, 2023. Other children of J.N.C. and M.T.C. were in the care of DCFS at this time.

On October 2, 2023, DCFS received a report that A.N.C. had been placed at risk of

harm as a result of drug exposure through breastfeeding. DCFS was unable to assess

the welfare of A.N.C. because the parents denied DCFS access to A.N.C. DCFS

obtained an Instanter Order to bring A.N.C. into the State’s custody. That order was

signed on October 16, 2023. After coming into foster care, A.N.C. was placed in

the home of the mother’s brother. A.N.C. was adjudicated a child in need of care

(CINC) and the adjudication order was signed on December 29, 2023.

A case plan dated March 20, 2024, was established by DCFS and approved

by the court at the review hearing on April 18, 2024. The court concluded that DCFS

had provided reasonable efforts toward reunification and continued custody of

A.N.C. with DCFS. On May 1, 2024, A.N.C. was placed in a certified adoptive

placement with fictive kin. A permanency hearing was held on October 17, 2024,

during which the court accepted the case plan filed by DCFS on October 3, 2024,

with a recommended goal of adoption. The court concluded that DCFS had made

reasonable efforts and continued custody of A.N.C. with DCFS.

DCFS filed a Petition for Termination of Parental Rights and Certification for

Adoption on June 20, 2024. A termination hearing was held, and the trial court heard

the testimony of both parents and the DCFS case worker assigned to the case, Ikeia

Johnson. The trial court granted DCFS’s petition and M.T.C. and J.N.C.’s parental

rights were terminated by judgment rendered on September 18, 2024. Both parents

filed timely motions for appeal which were granted on October 7 and 8 of 2024.

2 On May 28, 2025, this court rendered an opinion in State in Interest of A.N.C.,

24-679 (La.App. 3 Cir. 5/28/25), 416 So.3d 728, which partially reversed the

judgment due to a procedural error involving the record. This court was unable to

discern whether the trial court examined the 2023 CINC record pertaining to A.N.C.

or whether the trial court examined the 2022 CINC record pertaining to the

biological siblings of A.N.C. As a result, this court reversed the judgment to the

extent that parental rights were terminated and remanded for further proceedings.

The trial court held a pre-trial hearing on July 10, 2025, to ascertain what

issues were before the court on remand. At the pre-trial hearing, it was noted that

when the clerk was preparing the record for the 2024 appeal, the clerk entered an

amended minute entry to correct the docket number on the exhibit that was admitted

during the termination hearing, believing it to be an error. The remanded termination

hearing was held July 31, 2025. The evidence admitted included this court’s opinion

rendered on May 28, 2025, the transcript of the original hearing, the 2022 CINC

record, and the 2023 CINC record pertaining to both A.N.C. and her siblings. The

trial court also took judicial notice of all testimony adduced at the original hearing.

No new testimony was offered at the hearing. The trial court took the matter under

advisement. On August 4, 2025, the trial court issued written reasons for judgment,

and a final judgment terminating the parental rights of J.N.C. and M.T.C. and freeing

A.N.C. for adoption was signed on August 29, 2025. J.N.C. and M.T.C. timely filed

motions for appeal which were granted September 12, 2025. A motion to enroll

appellate counsel was filed September 25, 2025, and granted September 26, 2025.

3 III.

STANDARD OF REVIEW

A judgment terminating parental rights is reviewed under the manifest error

standard of review. State in the Interest of M.J.F., 18-584 (La.App. 3 Cir. 12/6/18),

261 So.3d 879.

A trial court’s factual determinations as to whether there has been substantial compliance with a case plan, whether a significant indication of reformation has been shown, and whether the parent is likely to reform will not be set aside unless the record reflects that the trial court is clearly wrong.

State ex rel. G.O., 10-571, pp. 5–6 (La.App. 3 Cir. 6/8/11), 68 So.3d 636, 640, writ

denied, 11-1512 (La. 7/21/11), 67 So.3d 479.

IV.

LAW AND DISCUSSION

Motion to Strike

J.N.C. and M.T.C. seek to strike portions of the exhibits in the appellate record

which occurred after the July 31, 2025 termination hearing. Louisiana Code of Civil

Procedure Article 2164 provides that the appellate court shall render any judgment

which is just, legal, and proper upon the record on appeal. “The record on appeal is

that which is sent by the trial court to the appellate court and includes the pleadings,

court minutes, transcript, jury instructions, judgments and other rulings, unless

otherwise designated. La.Code Civ.P. arts 2127 and 2128.” Frank v. Frank, 06-

1223, pp. 6–7 (La.App. 3 Cir. 2/7/07), 948 So.2d 1224, 1228. Our review on appeal

“is limited strictly to the record as it existed at the time the underlying judgment was

rendered.” Capital City Press, L.L.C. v. Louisiana State Univ. Sys. Bd. of Sup’rs,

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Related

State in Interest of AC
643 So. 2d 719 (Supreme Court of Louisiana, 1994)
Frank v. Frank
948 So. 2d 1224 (Louisiana Court of Appeal, 2007)
Guinn v. Kemp
136 So. 764 (Louisiana Court of Appeal, 1931)
State ex rel. J.A.
237 So. 3d 69 (Louisiana Court of Appeal, 2018)

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