State in the Interest of J.A.

CourtLouisiana Court of Appeal
DecidedJanuary 4, 2018
DocketJAC-0017-0500
StatusUnknown

This text of State in the Interest of J.A. (State in the Interest of J.A.) 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 J.A., (La. Ct. App. 2018).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-500

STATE IN THE INTEREST OF J.A.

**********

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN, NO. 15-JV-017866 HONORABLE CURTIS SIGUR, DISTRICT JUDGE

PHYLLIS M. KEATY JUDGE

Court composed of Marc T. Amy, Shannon J. Gremillion, and Phyllis M. Keaty, Judges.

AFFIRMED.

S. Marie Johnson Public Defender’s Office 106 West Berard Street St. Martinville, Louisiana 70582 (337) 394-1446 Counsel for Appellant: D.A. (mother)

Diane E. Cote Attorney at Law 825 Kaliste Saloom Road Brandywine III, Room 150 Lafayette, Louisiana 70508 (337) 262-5913 Counsel for Appellee: State of Louisiana, Department of Children & Family Services Jocelyn Sias The Sias Firm, LLC 203 West Main Street, Suite 105 New Iberia, Louisiana 70560 (337) 321-9516 Counsel for Appellee: J.B. (father)

Denise Henderson Raveen Hill Mental Health Advocacy Service Child Advocacy Program 302 Dulles Drive, Suite U-47 Lafayette, Louisiana 70506 (337) 262-2030 Counsel for Appellee: J.A. (child) KEATY, Judge.

D.A.1 appeals the judgment of the trial court terminating her parental rights

to her minor child, J.A. For the following reasons, the trial court’s judgment is

FACTS & PROCEDURAL HISTORY

The mother, D.A., and the father, J.B., together produced one female child,

J.A., who was born on October 6, 2012. On December 28, 2014, the State of

Louisiana, Department of Children and Family Services (DCFS) received a report

that J.A. was an alleged victim of dependency, lacked parental supervision, and

lived in an inadequate shelter. Following an initial investigation into the

allegations, the DCFS recommended that it retain temporary custody of J.A., who

had been living with her mother in the home of her maternal grandmother, M.A.

An oral instanter order was issued placing J.A. in the temporary custody of the

DCFS on January 4, 2015. On January 7, 2015, a written instanter order with a

supporting affidavit was filed and signed by the trial court and contained the

information regarding DCFS’s investigation into the reported claims. On that

same date, a continued custody hearing was held which resulted in the trial court

signing a formal judgment maintaining custody of J.A. with the DCFS. On

January 8, 2015, the State filed a Petition of Child in Need of Care alleging that

J.A. was a victim of neglect as defined under La.Ch.Code art. 603(18), secondary

to the mother’s substance abuse and mental health illness along with the absence of

the father. The allegations contained in the petition were denied by D.A. at the

answer hearing on February 12, 2015. The trial court thereafter granted the State’s

request in its petition.

1 Pursuant to Uniform Rules—Courts of Appeal, Rules 5–1 and 5–2, the initials of the parties will be used to protect and maintain the privacy of the minor children involved in the proceeding. Following an adjudication hearing and pursuant to the trial court’s written

judgment dated March 10, 2015, J.A. was adjudicated a child in need of care. The

trial court found that it was in J.A.’s best interest to remain in the custody of the

DCFS. The written judgment advised D.A. of the case review and permanency

review procedure along with her obligation to cooperate with the department and

to comply with all of the case plan’s requirements. According to the judgment,

failure to comply with the case plan could result in termination of parental rights.

Thereafter, multiple permanency review hearings occurred wherein the trial

court was presented with a DCFS case plan, DCFS progress reports, and

supporting evidence. Initially, the DCFS formulated a court-approved case plan

outlining a strategy for reunification between D.A. and J.A. The strategy for

reunification subsequently changed to adoption based upon D.A.’s continued

substance abuse and mental health issues.

On May 3, 2016, the DCFS filed a formal Petition for Termination of

Parental Rights and Certificate of Adoption, seeking to terminate D.A. and J.B.’s

parental rights and clear the way for the foster parent to adopt J.A. Trial on the

petition occurred on August 19, 2016. After considering the testimony and

evidence offered at trial, the trial court orally terminated the father’s parental rights

and continued the matter with respect to the termination of D.A.’s parental rights.

The matter proceeded to trial on October 31, 2016. After hearing the testimony

and evidence presented, the trial court terminated D.A.’s parental rights for reasons

stated in open court. It subsequently issued a written Judgment of Termination of

Parental Rights and Certification for Adoption on November 16, 2016, terminating

the parental rights of both parents. D.A. appealed.

The appeal was lodged with this court on May 30, 2017. On May 31, 2017,

we issued a rule for D.A. to show cause why the appeal should not be dismissed as 2 untimely filed. Based on the allegations contained in the Appellant’s response

brief, this court ordered a limited remand to allow the trial court to conduct a

contradictory hearing on the untimeliness issue. State in Interest of J.A., 17-500

(La.App. 3 Cir. 6/28/17), 224 So.3d 411. According to trial court’s minutes dated

August 18, 2017, which is in the supplemental record on review, the trial court

found that D.A.’s appeal was timely filed.

On appeal, D.A. contends that the trial court erred in granting judgment in

favor of the DCFS, terminating her parental rights.

STANDARD OF REVIEW

“In a termination proceeding, the appellate court will not set aside the trial

court’s findings of fact unless it was manifestly erroneous.” State in Interest of

J.M.L., 47,201, p. 5 (La.App. 2 Cir. 4/11/12), 92 So.3d 447, 450. Questions of fact

in a proceeding for termination of parental rights include the “issue of parental

compliance with a case plan, the parent’s expected success of rehabilitation, and

the expectation of significant improvement in the parent’s condition and conduct.”

Id.

DISCUSSION

In her assignment of error, D.A. contends that the trial court erred in

granting judgment in favor of the DCFS, terminating her parental rights.

A parent has a constitutionally protected liberty interest in establishing and

maintaining a meaningful relationship with his or her children. State in Interest of

A.C., 93-1125 (La. 1/27/94), 643 So.2d 719. This parental interest includes the

“care, custody, and management of their child.” State ex rel. J.M., 02-2089, p. 7

(La. 1/28/03), 837 So.2d 1247, 1252. Consistent with the parental interest, the

state has a legitimate interest in limiting or terminating parental rights under

certain conditions. Id. Because termination of parental rights is a severe action, 3 the state bears the burden of establishing each element of a ground for termination

by clear and convincing evidence. La.Ch.Code art. 1035; State ex rel. B.H. v. A.H.,

42,864 (La.App. 2 Cir. 10/24/07), 968 So.2d 881. The statutory grounds for

involuntary termination of parental rights are found in La.Ch.Code art. 1015,

although “only one ground need be established.” State ex rel. B.H., 968 So.2d at

885. Once a ground for termination has been established, the parental rights may

be terminated by the trial court if it is in the child’s best interest. Id.; La.Ch.Code

art. 1037.

In this case, the trial court’s written judgment states that the DCFS “met its

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Related

State in Interest of AC
643 So. 2d 719 (Supreme Court of Louisiana, 1994)
State ex rel. M.C.
194 So. 3d 1235 (Louisiana Court of Appeal, 2016)
State ex rel. J.A.
224 So. 3d 411 (Louisiana Court of Appeal, 2017)
State ex rel. J.M.L.
92 So. 3d 447 (Louisiana Court of Appeal, 2012)

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