State of Louisiana in the Interest of K.P. and S.P

Louisiana Court of Appeal·Decided June 18, 2026·No. 2026 CU 0237·Unknown

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2026 CJ 0237

STATE OF LOUISIANA IN THE INTEREST OF K.P., AND S. P.

JUDGMENT RENDERED. JUN 18 2026

On Appeal from the 22"' Judicial District Court In and for the Parish of St. Tammany State of Louisiana Docket No. JC -0302- 2024 - Division G

Honorable Scott C. Gardner, Judge Presiding

Alexis G. McElveen Counsel for Appellant, New Orleans, Louisiana Ka.P. — Mother and

Jane Hogan Hammond, Louisiana

Whitney Germany Counsel for Appellee, Covington, Louisiana Ke.P. — Father

Sandra Baum Terrell Counsel for Appellee, Covington, Louisiana State of Louisiana Department of Children and Family Services

Betsy H. Smith Counsel for Appellee, Mandeville, Louisiana K.P. and S. P. — Children

BEFORE: THERIOT, BALFOUR, AND HAGGERTY' q JJ.

I Judge Bryan D. Haggerty serving pro tempore by special appointment of the Louisiana Supreme Court. BALFOUR, J.

A mother, Ka.P., appeals a judgment terminating her parental rights and

certifying the minor children, K.P. and S. P., for adoption.' For the following

reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

K.P., born December 9, 2019, and S. P., born September 26, 2021, entered the

State' s custody on September 3, 2024, pursuant to an instanter order for removal.

According to the affidavit in support of the instanter order the Department of

Children and Family Services (DCFS) received a report initiated by the father, Ke.P.

on August 19, 2024, of alleged "Neglect/Lack of Adequate Supervision." According

to Ke.P., when he returned home after being released from prison, he found piles of

trash in the home and stated that the mother, Ka.P. had left the children and had not

been seen by anyone in two weeks. At the time, K.P. was five years old and S. P. was

three years old. He also suspected that the mother was using narcotics. The children

had been in the custody of the State in the past due to both Ke.P. and the mother

using narcotics. Ke.P. stated he was not able to care for the children. On September

24, 2024, the District Attorney for the 22nd Judicial District Court filed a child in

need of care ( CINC) petition, asserting therein " the child[ ren] [ are] a victim of

neglect." The paternal grandparents advised DCFS that they had already been caring

for the children for at least two weeks as they located the mother. They agreed to

continue custody of K.P. and S. P.

Both parents were absent when the matter came for a case review hearing on

April 14, 2025. The custody for K.P. and S. P. was maintained with the State, and

the continued placement with their paternal grandparents was still in the best interest

of the children. At the disposition hearings on October 14, 2024, November 26,

2 The initials of the child and the parents are used to protect the identity of the minor child. See Uniform Rules -Courts of Appeal, Rules 5- 1 and 5- 2.

2 2024, January 26, 2025, and April 14, 2025, the trial court ordered that K.P. and S. P.

remain in the custody of the State and the court agreed to the goal of reunification.

However, eventually the trial court found that DCFS had made reasonable efforts to

unify the children with their parents. An initial permanency hearing was set for

August 26, 2025. At the permanency hearing, the Case Plan for K.P. and S. P. was

changed to adoption.

On October 8, 2025, DCFS filed a petition for termination of parental rights,

requesting the parental rights of Ka.P. and Ke.P. be terminated pursuant to La. Ch.

C. art. 1015, Sections 4( b) and 5. In the petition, DCFS alleged that neither parent

had substantially complied with the court -approved Case Plan for the safe return of

their children. Specifically, DCFS alleged that neither parent could provide a safe

and stable home for the children; the father was incarcerated again, and could not

provide a home for the children; the mother did not have a home that is adequate for

the children and at that time resided in a home where she sleeps on the couch —her

third residence throughout the life of the case. Neither parent paid parental

contributions for the children. Despite her income of $300. 00 per week, the Ka.P.

did not make any parental contributions. Ka.P. has transportation issues. Ka.P. is

participating in Family Preservation Center ( FPC), and she has been sober since

March 2025. She is addressing other aspects of her Case Plan through FPC. Ke.P.

has been incarcerated for most of the life of this case and he has not complied with

any of the action steps on his Case Plans for reunification. DCFS alleged the parents

exhibit a repeated pattern of substance abuse and instability that puts their children

at risk.

Ka.P. has been involved with DCFS on at least three occasions. She does not

3 have custody of any of her children. K.P. has been in DCFS custody on two

KaR lost custody of B. S., born on March 14, 2020. In that case, the father has custody. 3 occasions. On the first occasion, guardianship of K.P and S. P. was granted to the

maternal grandmother, who later returned him to Ka.P. without notifying DCFS.

K.P. was diagnosed with Autism Spectrum Disorder, which is being addressed by

the paternal grandparents and the school system. S. P. is also likely autistic but there

has been no formal diagnosis. Both children had significant developmental delays.

The paternal grandmother, M.P., takes them to their numerous appointments. The

children were found to be thriving with their paternal grandparents, and DCFS

concluded that the children would suffer greatly if returned to the parents. The

paternal grandparents wish to adopt them.

On November 19, 2025, Ka.P. filed "A Motion To Set Special Review" asking

the court to change the goal from adoption to reunification, and asked for an

extension of time pursuant to the " Adoption and Safe Families Act." See 42 U.S. C. A.

601, et seq.; La. Ch. C. art. 60. In support of her request, Ka.P. stated that part of

the goal change to adoption was her inability to obtain a driver' s license which was

remedied when she was able to obtain one in November 2025. She further asserted

that she has been substantially compliant with the Case Plan and has made

significant improvements in her conduct. The court ordered the parties to show

cause as to why the goal should be changed to reunification and set that hearing for December 10, 2025. On December 4, 2025, the Court Appointed Special Advocate

CASA) submitted a report recommending the parental rights be terminated. The

trial court held a hearing on the petition for termination of parental rights and Ka.P.' s

motion for special review on December 10, 2025. At the conclusion of the hearing,

the trial court granted the motion to terminate parental rights, freeing K.P. and S. P

for adoption. On December 15, 2025, the trial court signed ajudgment terminating

the parental rights with both Ka.P. and Ke.P. and certifying K.P. and S. P. for

adoption.

M Only the mother, Ka.P., appeals the December 10, 2025 judgment, arguing

the trial court erred: in terminating her parental rights due to non-compliance of her

Case Plan; in finding that DCFS made reasonable efforts to achieve reunification;

and in finding there was no reasonable probability of continued improvement in the

near future. Ka.P. also avers the trial court erred in terminating her parental rights

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