State in the Interest of D.E.C. & N.H.C.

CourtLouisiana Court of Appeal
DecidedApril 6, 2016
DocketJAC-0015-1138
StatusUnknown

This text of State in the Interest of D.E.C. & N.H.C. (State in the Interest of D.E.C. & N.H.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 D.E.C. & N.H.C., (La. Ct. App. 2016).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

15-1138

STATE IN THE INTEREST OF D.E.C. & N.H.C.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF ACADIA, NO. JU 6150 HONORABLE KRISTIAN DENNIS EARLES, DISTRICT JUDGE

SHANNON J. GREMILLION JUDGE

Court composed of Billy Howard Ezell, Shannon J. Gremillion, and David Kent Savoie, Judges.

AFFIRMED.

Jane Hogan Public Defender’s Office, Fifteenth Judicial District 600 Jefferson Street, Suite 902 Lafayette, LA 70501 (337) 232-9345 COUNSEL FOR APPELLANT: J.C. (father) Diane E. Cote 825 Kaliste Saloom Road Brandywine III, Room 150 Lafayette, LA 70508 (337) 262-5913 COUNSEL FOR APPELLEE: State of Louisiana, Department of Children & Family Services Chantel Conrad Acadiana Legal Services 1020 Surray St. Lafayette, LA 70501 (337) 237-4320 COUNSEL FOR APPELLEE: D.E.C. (child) N.H.C. (child)

Lucy Melancon Indigent Defender's Office P. O. Box 252 Crowley, LA 70527 (337) 889-5672 COUNSEL FOR APPELLEE: H.L. (mother) GREMILLION, Judge.

The father, J.C., appeals the trial court’s ruling terminating his parental

rights to his children D.E.C., born November 5, 2004, and N.H.C., born November

11, 20051 2

FACTUAL AND PROCEDURAL BACKGROUND

Pursuant to an October 2013 instanter order, D.E.C. and N.H.C. were

removed from J.C.’s grandparents’ home, where J.C. had been residing, and placed

in the State of Louisiana, Department of Children and Family Social Services’

custody (DCFS). The children were adjudicated in need of care and were placed in

foster care with their maternal aunt, G.F. The grandparents kicked J.C. out of their

home due to his ongoing drug use and because they could no longer care for the

children. J.C. was arrested on October 25, 2013 on domestic violence charges and,

at that time, tested positive for cocaine, marijuana, and opiates.

As in all cases in which DCFS has taken custody, a comprehensive and

detailed case plan was created for J.C. setting forth requirements for reunification

pertaining to housing, food, basic needs, the physical and mental health of the

parent, parental substance abuse, and the physical and mental health of the children,

among other things. Routine review hearings were held to apprise the trial court of

the status of the children and parents. DCFS filed a petition for termination of

parental rights and certification for adoption on May 28, 2015. Following a

termination hearing on September 16, 2015, J.C.’s parental rights were terminated

1 Pursuant to Uniform Rules—Courts of Appeal, Rule 5-2, initials are used throughout to protect the identity of the minor. 2 The mother stipulated to the termination of her parental rights at the same hearing. in a judgment filed October 6, 2015, and the children were freed for adoption. J.C.

now appeals and assigns as error:

1. The juvenile court erred in terminating the parental rights of J.C. under La.Ch.C. art. 1015(4) because J.C. did not abandon his children because he did not demonstrate an intention to permanently avoid parental responsibilities.

2. The juvenile court erred in terminating the parental rights of J.C. under La.Ch.C. art. 1015(5) because the agency failed to show by clear and convincing evidence that J.C. had failed to substantially comply with his case plan, that there was no reasonable likelihood of compliance in the near future, and that termination was in the best interest of the children.

LAW AND DISCUSSION

We have stated that ―[p]arental rights to the care, custody, and management

of children is a fundamental liberty interest warranting great deference and vigilant

protection under the law.‖ In re J.K., 97-336, p. 4 (La.App. 3 Cir. 10/29/97), 702

So.2d 1154, 1156. See also Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388

(1982). Accordingly, a parent has a strong interest in the accuracy of a decision to

terminate his rights. Lassiter v. Dep’t of Soc. Servs. of Durham Cnty., N.C., 452

U.S. 18, 101 S.Ct. 2153 (1981). Thus, the Louisiana legislature has imposed strict

standards that require the State to prove, by clear and convincing evidence, the

grounds for termination under La.Ch.Code art. 1015 before a judgment can be

issued terminating parental rights. In re J.K., 702 So.2d 1154.

This analysis requires a balancing of the child’s interests and the parent’s

interests; however, it has been repeatedly held that the interests of the child are

paramount to those of the parent. State ex rel. J.A., 99-2905 (La. 1/12/00), 752

So.2d 806. In that case, the supreme court stated:

The fundamental purpose of involuntary termination proceedings is to provide the greatest possible protection to a child whose parents are unwilling or unable to provide adequate care for his physical,

2 emotional, and mental health needs and adequate rearing by providing an expeditious judicial process for the termination of all parental rights and responsibilities and to achieve permanency and stability for the child. The focus of an involuntary termination proceeding is not whether the parent should be deprived of custody, but whether it would be in the best interest of the child for all legal relations with the parents to be terminated. As such, the primary concern of the courts and the State remains to secure the best interest for the child, including termination of parental rights if justifiable grounds exist and are proven. Nonetheless, courts must proceed with care and caution as the permanent termination of the legal relationship existing between natural parents and the child is one of the most drastic actions the State can take against its citizens.

Id. at 811 (citation omitted).

The trial court’s decision to terminate parental rights will not be reversed by

the appellate court unless it is manifestly erroneous or clearly wrong. In re V.F.R.,

01-1041 (La.App. 3 Cir. 2/13/02), 815 So.2d 1035, writ denied, 02-797 (La.

4/12/02), 813 So.2d 412.

Louisiana Children’s Code Article 1015(4) sets forth the following as

grounds for termination of a parent’s rights to his children:

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 permanently avoid parental responsibility by any of the following:

(a) For a period of at least four months as of the time of the hearing, despite a diligent search, the whereabouts of the child’s parents continue to be unknown.

(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.

(c) As of the time the petition is filed, the parent has failed to maintain significant contact with the child by visiting him or communicating with him for any period of six consecutive months.

Louisiana Children’s Code Article 1015(5) sets forth another ground for

involuntary termination of a parent’s rights to his children:

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Related

Santosky v. Kramer
455 U.S. 745 (Supreme Court, 1982)
State, in Interest of Jk
702 So. 2d 1154 (Louisiana Court of Appeal, 1997)
State ex rel. V.F.R.
815 So. 2d 1035 (Louisiana Court of Appeal, 2002)

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State in the Interest of D.E.C. & N.H.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-in-the-interest-of-dec-nhc-lactapp-2016.