State of Louisiana in the Interest of K.C.N

CourtLouisiana Court of Appeal
DecidedDecember 9, 2025
Docket2025 CJ 0167
StatusUnknown

This text of State of Louisiana in the Interest of K.C.N (State of Louisiana in the Interest of K.C.N) 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 of Louisiana in the Interest of K.C.N, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2025 CJ 016%

STATE OF LOUISIANA IN THE INTEREST OF K.C.N.

Judgment Rendered: EAMM

On Appeal from the 22nd Judicial District Court

w In and for the Parish of St. Tammany State of Louisiana Trial Court No. JC -0123- 2022

Honorable Scott Gardner, Judge Presiding

Douglas Lee Harville Attorneys for Appellant Shreveport, Louisiana K.J., father of K.C.N. Terrell L. Dupard Baton Rouge, Louisiana

Betsy H. Smith Attorney for Appellee Mandeville, Louisiana K.C.N.

Sandra B. Terrell Attorney for Appellee Covington, Louisiana State of Louisiana, Department of Children and Family Services

J. Collin Sims Attorneys for Appellee District Attorney District Attorney for the 22nd Brandi Dohre Judicial District Assistant District Attorney Covington, Louisiana

BEFORE: PENZATO, STROMBERG, AND FIELDS, JJ. PENZATO, J.

A father appeals a judgment terminating his parental rights. For the following

reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

K.C.N. was born on April 19, 2022, to A.N. while she was incarcerated at the

St. Tammany Parish Jail. The Department of Children and Family Services (DCFS)

received a report concerning K.C. N., as he was without a legal caretaker while A.N.

remained in prison. A.N. was unwilling to provide information needed to ascertain

the identity of K.C.N.' s father or possible family members. DCFS sought an

instanter order, which was orally granted by the trial court on April 22, 2022, placing

K.C.N. in the provisional custody of DCFS.

The District Attorney of the 22" d Judicial District Court, State of Louisiana,

filed a child in need of care petition, and on June 22, 2022, the trial court adjudicated

K.C.N. in need of care, ordered that K.C.N. remain in state custody, and approved

DCFS' s case plan with the goal of reunification. However, following an initial

permanency hearing on April 19, 2023, the trial court approved the change of the

case plan goal to adoption, finding adoption to be in the best interest of K.C.N.1

Around the time of the permanency hearing, K.J. was identified as K.C. N.' s

potential father, and in June of 2023, DNA testing established him as the father. On

July 5, 2023, K.J. was added to the child in need of care case by way of an amending

petition. On November 2, 2023, K.J. filed a motion to vacate the adjudication of

K.C.N. as a child in need of care and/or to modify the disposition to grant custody

of K.C. N. to K.J. The motion came for hearing on November 29, 2023, along with

a case review. K.J. testified at the hearing that he lived in New Orleans with his

1 Ultimately, the parental rights of A.N. were terminated on August 25, 2023. A.N. unsuccessfully appealed the termination of her parental rights in a prior appeal. See State in Interest of KC.N., 2023- 1144 ( La. App. 1 Cir. 5/ 29/24), 2024 WL 2746505 ( unpublished), writ denied, 2024- 00837 La. 9/ 4/ 24), 391 So. 3d 1059, cert. denied sub nom., AN. v. Louisiana Department of Children and Family Services, U.S., 145 S. Ct. 2708, 221 L.Ed.2d. 970.

M sixteen -year- old daughter. He testified that he had twelve children, with another due

in January, and the parties stipulated that " there may have been many of those

children who [ were] not raised solely by him." According to K.J., he had never paid

child support for any of his children. He testified that he received $ 980. 00 per month

in social security and SSI and made additional income breeding and selling "bullies,"

but did not report that income. K.J. testified he had been arrested " a few times" and

been in jail a few times." Evidence introduced at the hearing showed that he pled

guilty to three counts of distribution of heroin in 2015 and served four years in

federal prison. He also pled guilty to aggravated battery and attempted possession

of a firearm in 1996, and in 2002 he pled guilty to possession of heroin, for which

he was sentenced to five years in prison. In 2020, he was arrested on charges of

domestic abuse battery, and pled guilty to the lesser offense of disturbing the peace.

K.J. testified that since he learned he was K.C.N.' s father, he had seen K.C. N. two

or three times, " for like, an hour." When asked why he believed it would be

appropriate for him to have custody of K.C.N., K.J. answered, " He' s my son." At

the conclusion of the hearing, K.J. withdrew the motion to vacate the adjudication

and/ or modify the disposition. The case review judgment, signed December 18,

2023, ordered that K.C.N. remain in the custody of DCFS and that the goal of

adoption continued to be approved and accepted.

A permanency review hearing for K.J. was held on April 10, 2024. Following

the hearing, the trial court found that DCFS had made reasonable efforts to reunify

the parent and child, considering the child' s health and safety, and continued with

the plan for adoption of K.C.N.'

On June 7, 2024, a petition for termination of K.J.' s parental rights was filed

on behalf of K.C. N., asking that K.J.' s rights be terminated pursuant to La. Ch.C.

2 K.C.N. remained in the same certified foster home since birth.

0 art. 1015( 4)( b), 3 for abandonment of K.C.N. by failing to provide significant

contributions to his care and support for the period of July 5, 2023 through January

2% 2024.

The trial court held a hearing on the petition for termination of parental rights

on September 25, 2024. At the conclusion of the hearing, the trial court ordered the

parties to file post -trial briefs. Thereafter, the trial court signed a judgment on

October 7, 2024, terminating K.J.' s parental rights pursuant to La. Ch.C. art.

1015( 4)( b), finding that it was in K.C.N.' s best interest pursuant to La. Ch.C. art.

1037, as he was thriving in his current adoptive placement. The trial court issued

reasons for judgment on October 10, 2024.

K.J. appeals, contending the trial court erred in finding he failed to make

parental contributions for any six-month period prior to the filing of the petition to

terminate K.J.' s parental rights and that termination was in K.C.N.' s best interest.

DISCUSSION

Title X of the Louisiana Children' s Code governs the involuntary termination

of parental rights. Under La. Ch.C. art. 1001, the purpose of a termination of parental

rights proceeding is to protect children whose parents are unwilling or unable to

provide safety and care adequate to meet their physical, emotional, and mental health

needs. In all proceedings, the primary concern is to secure the best interest of the

child if a ground justifying termination of parental rights is proved. Termination of

parental rights is to be considered the first step toward permanent placement of the

child in a safe and suitable home, and if possible, to achieve the child' s adoption.

The interests of the parent must be balanced against the child' s interest, but the

child' s interest is paramount. State in Interest ofCE, 2017- 1054 ( La. 12/ 6/ 17), 235

3 Louisiana Children' s Code article 1015 was amended by La. Acts 2023, No. 271, § 1, effective June 9, 2023. Act 271 renumbered article 1015, such that subparagraph ( 5) is now subparagraph 4). The petition incorrectly referred to this section as Article 1015( 5)( b).

11 So. 3d 1066, 1075. More than simply protecting parental rights, our judicial system

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State of Louisiana in the Interest of A.L.D. and L.S.D.
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State of Louisiana in the Interest of K.C.N, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-in-the-interest-of-kcn-lactapp-2025.