State in the Interest of J.F., J.F. and A.F.

CourtLouisiana Court of Appeal
DecidedMay 23, 2007
DocketJAC-0006-1484
StatusUnknown

This text of State in the Interest of J.F., J.F. and A.F. (State in the Interest of J.F., J.F. and A.F.) 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.F., J.F. and A.F., (La. Ct. App. 2007).

Opinion

DO NOT PUBLISH

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-1484

STATE IN THE INTEREST OF J. F., J. F. AND A. F.

********** APPEAL FROM THE OPELOUSAS CITY COURT FOR THE PARISH OF ST. LANDRY, NO. JV-7033 HONORABLE KENNETH BOAGNI, JR., CITY COURT JUDGE

**********

J. DAVID PAINTER

********** Court composed of Oswald A. Decuir, Elizabeth A. Pickett, and J. David Painter, Judges.

VACATED AND REMANDED.

J. J. F., Sr. 937 Jordan St. Opelousas, LA 70570 Defendant-Appellant, Pro Se

Chris Richard 730 Jefferson St. Lafayette, LA 70501 Counsel for Defendant-Appellant: P. N.

Lauren Mouret 115 N. Court St. Opelousas, LA 70570 Counsel for J. F., Jr., J. F. and A. F.

L. Antoinette Beard 825 Kaliste Saloom Road., Bldg. 1, Rm. 218 Lafayette, LA 70501 Counsel for Plaintiff-Appellee: Department of Social Services PAINTER, Judge.

J. F., Sr. appeals the trial court’s judgment granting guardianship of his three

minor children to their paternal grandmother with a permanent plan that she remain

guardian until each child reaches the age of eighteen.

FACTS

In May 2001, a petition was filed to declare J.F,, Jr., then seven years old, a

child in need of care. His father, J. F., Sr., was given custody and supervision was

deemed unnecessary. In February 2004, the Office of Community Services (OCS)

received a report that J.F., Jr. had been sexually molested by his uncle while at the

home of his paternal grandmother and that, on another occasion, the mother, P. N.,

had left her three children, aged 10, 2-1/2 and 2 locked in her house for at least fifteen

minutes while she went to a neighbor’s house to seek medical attention for her

asthma. At that time J.F., Sr. had apparently ceded custody of J. F., Jr. to P. N.

because of inability to care for the child’s needs. In May 2004, a petition was again

filed to have J. F., Jr. declared a child in need of care. In August 2004, P. N. was

given custody of J. F., Jr. because of J. F., Sr.’s admission that he could not care for

the child. The judgment made no mention of supervision. For the next year, the

family’s progress reports indicated that the family was making significant progress

and cooperating with the agency.

On February 22, 2005, the OCS received a call from P. N. indicating that she

and one of the children needed emergency medical treatment for asthma. On

February 24, 2005, an affidavit in support of an instanter order was filed with the

Opelousas Juvenile City Court by the OCS. The instanter order was issued, and J. F.,

Jr., and his younger siblings, J. F., and A. F. were taken into the custody of the State

1 through the Department of Social Services and placed in foster care. A hearing on

the order was held on February 28, 2005. No transcript was made of the hearing but,

according to a minute entry, all parties were present with counsel, and the case was

set for a forty-five day hearing. A petition was filed to have the children declared in

need of care, and an order of continued custody was signed on February 28, 2005,

continuing the children in the care of the State. A case plan was filed with the court

on March 25, 2005. By the time the forty-five day hearing was held on April 6, 2005,

counsel for J. F., Sr. was apparently no longer able to practice law, and J. F., Sr. was

allowed to represent himself. Custody was again continued with the State. Five more

review hearings were held at which representatives from the OCS and the parties

testified. J. F., Sr. continued to represent himself. Counsel for the remaining parties

were present but rarely, if ever, participated. OCS case workers reported that P. N.

had an ongoing drug problem evidenced by positive drug screens and that J. F., Sr.

was refusing to work to achieve the goals set in the case plan by failing to get

counseling regarding the sexual abuse of his son, J. F., Jr., in failing to participate in

parenting classes, in failing to participate in a domestic violence program, and in

failing to submit to periodic drug testing. J. F., Sr. continued to object to the plan.

During this period however, J. F., Sr. was working, found a place to live in which the

children could be accommodated, and found daycare and school placements for the

children. Additionally, his psychological report, dated April 2005, was generally

positive and suggested that a trial placement of the children with him would be

feasible. The final hearing, held on March 8, 2006, was designated a review hearing

but was, in fact, a permanency hearing. See La.Ch.Code art. 702. It resulted in the

children being placed in the care of their paternal grandmother. The judgment stated

2 that: “this guardianship shall remain in effect until the child’s eighteenth (18th)

birthday, as provided by Louisiana Children’s Code or is otherwise modified by this

Court, and that this is the Permanent Plan for the child.”

J. F., Sr. appeals asserting that his due process rights have been violated. After

reviewing the record, we agree.

DISCUSSION

In Santosky v. Kramer, 455 U.S. 745, 753, 102 S.Ct. 1388, 1394-95, 71 L.Ed.2d 599 (1982), the United States Supreme Court recognized that natural parents have a fundamental liberty interest in the care, custody, and management of their child and that the natural parents’ interest does not “evaporate simply because they have not been model parents or have lost temporary custody of their child to the State.” The Court went on to acknowledge that, while the State has an “urgent interest” in a child’s welfare and in providing the child with a permanent home, as long as there is reason to believe that a positive, nurturing parent-child relationship exists, the State’s interest must favor preservation over severance of natural familial bonds. Id. at 766, 102 S.Ct. at 1401 (quoting Lassiter v. Department of Soc. Servs., 452 U.S. 18, 27, 101 S.Ct. 2153, 68 L.Ed.2d 640 (1981)). Thus, the Court found that parents who are faced with the possibility of forced dissolution of their parental rights must be provided with fundamentally fair procedures in order to ensure that children’s legal bonds are not erroneously severed from fit parents. Id. at 753-54, 102 S.Ct. at 1395.

State ex rel. G.J.L., 00-3278, p. 5 (La.6/29/01), 791 So.2d 80, 84 (emphasis added).

The Louisiana Children’s Code set forth the procedures required for removing children in need of care from the custody of their parents and the procedures that must be followed to reunify the children with their parents or terminate their parental rights. “Because due process requires that a fundamentally fair procedure be followed when the State seeks to terminate the parent-child legal relationship, actions to terminate must be scrutinized very carefully.” Id. at 85.

State in Interest of P.A.R., 06-423, pp 3-4 (La.App. 3 Cir. 10/18/06), 942 So.2d 57,

60.

3 Examination of the record in this case has revealed several instances in which

failure to comply with the procedure set out in the Children’s Code may have

impacted the due process rights of the parties. However, because the trial court’s

failure to determine whether J. F., Sr.’s waiver of his right to appointed counsel was

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Related

Santosky v. Kramer
455 U.S. 745 (Supreme Court, 1982)
Iowa v. Tovar
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Hill v. Hill
944 So. 2d 873 (Louisiana Court of Appeal, 2006)
State v. Johnson
944 So. 2d 864 (Louisiana Court of Appeal, 2006)
State, in Interest of Howard
382 So. 2d 194 (Louisiana Court of Appeal, 1980)
State v. Simmons
924 So. 2d 137 (Supreme Court of Louisiana, 2006)

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