There are two issues addressed in the present appeal: (1) whether counsel e-filing the notice of appeal for the TPR (termination of parental rights) case in a related DNA (dependency, neglect, abuse) case was sufficient to meet procedural rules; and (2) whether substantial evidence existed in the family court case to support the court’s termination of D.W.’s parental rights of N.W. as being in N.W.’s best interest.

First, D.W.’s counsel for this appeal filed a notice of appeal in a related DNA case for the child, rather than in the TPR case.  TPR cases are sealed cases following entry of an order; therefore, e-filing is not available for completed TPR cases per Kentucky Supreme Court Amended Administrative Order 2018-11 Section 9(3) and said filings much be conventionally filed.  D.W.’s counsel attempted to make this filing within ten (10) minutes of the filing deadline, only to encounter this procedural trap.  D.W.’s counsel then filed the notice of appeal in a related DNA case.  The Court of Appeals determined there are ambiguities in the e-filing rules, and therefore determined to proceed with the merits of the appeal.

Second, the Court analyzed the extent of substantial evidence the family court utilized in making its decision to terminate D.W.’s parental rights for N.W.  There is a three-part test that must be satisfied by clear and convincing evidence: (1) the child must be adjudged neglected or abused; (2) termination of the parent’s rights must be in the child’s best interest; and (3) one of the conditions outlined in the statute regarding grounds for involuntary termination of parental rights must be met.

D.W. does not disagree that (1) and (3) above were properly established at the family court level.  However, D.W. argues the Cabinet “did not show – by clear and convincing evidence – that termination of his parental rights is in N.W.’s best interest pursuant to KRS 625.090(1)(c).”  The Court agreed with this argument, finding there is insufficient evidence in the family court case to show “that D.W.’s convictions are directly related to the 2018 adjudication of educational neglect; and furthermore, the court specifically found that it could not conclude that D.W. had abandoned the child.”  Moreover, the Court discussed the extent of D.W.’s incarceration as it relates to abandonment, compelling termination of his parental rights.  Ultimately, the Court held there was not a basis to show that termination of D.W.’s parental rights was in N.W.’s best interest.

Judge Goodwine dissented on both issues.  First, Judge Goodwine noted the e-filing rules are not ambiguous and the majority’s opinion invites other counsel to rely on the case as precedent in not following the bright line rules for e-filing.  Second, Judge Goodwine opined the family court “painstakingly went through the evidence presented at trial and the statutory requirements of KRS Chapter 625 and methodically detailed her findings and conclusions. . .,” thereby concluding the family court met the necessary standard to terminate D.W.’s parental rights.

Caitlin P. Kidd, Esq.

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No. 2021-CA-0580-ME

Boyd County Circuit Court

The Cabinet for Health and Family Services (“CHFS”) appealed an order granting custody of a minor child to Grandmother and Uncle of the minor child due to the family members lacking standing to pursue such custody order.  The Kentucky Court of Appeals reversed and remanded the matter with instructions that the custody order issued by the circuit court is voidable, suggesting the family members’ petition for custody be dismissed.

Mother gave birth to twins born addicted to drugs.  Father only visited the twins once in the hospital, where he had an individual take a photo of him with the twins.  Notably, Father did not share this photo with his own mother for more than half a year later.  His mother (Grandmother of twins) shared the photo with Father’s half-brother (Uncle of twins).  CHFS inevitably became involved in the case very early due to the twins’ addiction to drugs and their subsequent month-long stay in the neonatal intensive care unit.  After CHFS quickly transferred the case from Lawrence County to Boyd County, Kentucky, CHFS petitioned the Boyd County District Court for a dependency, neglect, and abuse (“DNA”) action and was awarded emergency custody of the twins.  Both twins were placed with a foster family. 

At the adjudication hearing, the district court found neglect against the parents due to abandonment.  CHFS prepared a dispositional report that the permanency goal was reunification with the biological parents, if feasible.  However, the district court disposition order recommended termination of parental rights and adoption for the twins due to the parents’ abandonment. Importantly, neither Mother nor Father made recommendations to CHFS for suitable family members that may be willing to take temporary custody of the twins during the pendency of these proceedings. 

CHFS was notified by an Ohio child protective services worker that their organization was working with Mother and Father to place another one of their children with Grandmother and Uncle in Michigan.  CHFS was not provided with any contact information for Grandmother and Uncle.  At that time, CHFS conducted a search for relatives of the twins, which was supposed to have been completed at the outset of the case.  This search did not identify Grandmother and Uncle, so they were not contacted regarding the twins.

Shortly thereafter, CHFS initiated a termination of parental rights action against Mother and Father due to their arrests for trafficking fentanyl in Ohio.  Following the parents’ arrests, Grandmother and Uncle began contacting CHFS to pursue custody of the twins. The DNA matter continued as usual with the permanency goal of termination of parental rights, ultimately leading to adoption for the twins by, presumably, the foster family. 

Grandmother and Uncle retained counsel and petitioned the Boyd County Circuit Court for custody of the twins.  The guardian ad litem (“GAL”) for the twins and the parents recommended placement of the twins with Grandmother and Uncle; however, CHFS challenged standing for the custody petition.  The circuit court recommended Grandmother and Uncle’s petition for custody of the twins be granted.  CHFS filed exceptions following this decision.  The circuit court issued written findings imposing its decision that Grandmother and Uncle had standing due to CHFS’ failure to follow protocol, citing sua sponte that there was an equitable estoppel argument that defeats CHFS’ lack-of-standing defense.  Following, the district court, by the circuit court issuing a custody order, struck the DNA cases from the docket.

CHFS appealed the circuit court’s order that Grandmother and Uncle have standing to petition for custody of the twins.

The circuit court primarily utilized a Kentucky Supreme Court case, Baker v. Webb, to support its decision.  The Court of Appeals determined the circuit court incorrectly applied the case to the present facts, noting that “because standing and intervention are two distinct concepts, Baker is distinguishable on its face.”  The Court explained the facts presented in Baker differ from the facts presented in this case due to the timing of the family members’ involvement (i.e., whether there was a present or a past interest).  The Court clarified that Grandmother and Uncle’s “interest under KRS 620.090(2), if it ever existed, lapsed before they filed their petition in circuit court,” and that the parties “were not known to the Cabinet until long after the order of temporary custody was replaced by the order of commitment entered at the dispositional hearing.”  As a result, the Court held that there was not a present interest at hand when Grandmother and Uncle filed their petition for custody of the twins as the twins were not subject to an order of temporary custody under KRS 620.090(1).

As a side, the Court found the circuit court’s sua sponte use of equitable estoppel as a defense to CHFS’ lack-of-standing argument had no basis.  The parties never asserted an equitable estoppel defense, and even if they would have, the Court predicted the parties would not have been successful in their defense.  In support, the Court noted there was not conduct that lends to “misrepresentation or concealment of material facts upon which [Grandmother and Uncle] relied.”  

The Court ultimately held that the Boyd Circuit Court’s order awarding custody of the twins to Grandmother and Uncle be reversed and remanded with instructions to the lower court to dismiss their petition for custody.

Caitlin P. Kidd

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Madison Circuit Court

On July 22, 2020, Grandparents of the Child in this matter initiated filed a “Verified Petition for Termination of Parental Rights and Adoption.” After conducting an evidentiary hearing, the family court entered a finding of facts and conclusion of law alongside a “Judgement of Termination of Parental Rights.” The Biological Mother appealed the ruling.

Before addressing the Mother’s arguments, however, the Court felt it necessary to address a “subject of ongoing confusion in this critical area of legal practice.” The Court explained that filing a dual petition for adoption and termination, together, was procedurally improper. While the family court allowed this mistake to move forward, the Court emphasized that it is an “either/or” choice in petitioning for an adoption versus parental termination. Nevertheless, because KRS 199 encompasses KRS 625, the Court determined that the adoption analysis supersedes the termination analysis; thus, the Court would need to ensure that the erroneously allowed “Judgement of Termination of Parental Rights” met all the requirements of an adoption proceeding. Ultimately, the Court found the judgement erroneously named the birth parents, contrary to the instructions in KRS 199, but otherwise met all the other statutory requirements of an adoption.

When looking at the Mother’s substantive arguments, the Court found that the Mother failed to preserve her arguments properly under CR 76.12. Despite the noncompliance, the Court allowed review due to the sensitive nature of the case. The Mother’s arguments, however, were still barred. Generally, the Mother contested that the judgment failed to meet the requirements of KRS 199. The Court, however, after conducting a factor-by-factor analysis, found the family court’s findings adequately supported an adoption without consent. The Mother’s additional arguments, stating the family court’s findings were not supported by clear and convincing evidence and that the adoption was not in the child’s best interests, were nothing more than an attempt to re-argue her initial case. The Court, being satisfied in its review of the record, found the entry of a judgment of adoption substantively satisfied. Accordingly, the Court vacated the judgment, remanding the matter to the family court with two instructions: (1) that it correct its error with respect to erroneously naming the birth parents in its judgment and (2) that it enter a judgment of adoption, and not termination, in accordance with the requirements of KRS 199.520.

K. Spencer Pierson

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Warren Circuit Court

This decision concerns the biological Mother of the Child, born in January 2011. The Mother, suffering from substance use disorder, had a criminal history starting in 2009, that had her intermittently imprisoned from then to 2017. First cousin of the Mother, J.E.B., and his wife, D.J.B (Appellees), eventually received permanent custody of Child after Mother’s voluntary granting of guardianship. Mother retained visitation rights at Appellees’ discretion. In April of 2018, Appellees filed a petition to terminate all biological parental rights of the Child and to adopt the Child without the consent of biological parents under KRS 199.502(1). Finding that the Mother had abandoned Child for a period of no less than 90 days during a period of her not being incarcerated, the family court granted the petition under KRS 199.502(1)(a). The Mother appealed the judgement, but the Court of Appeals affirmed, finding clear and convincing evidence of the family court’s finding of abandonment. The Mother subsequently requested review by the Supreme Court of Kentucky, arguing two positions: first, that the family court erred in granting the petition for adoption when the Cabinet of Health and Family Services (“the Cabinet”) did not initiate a proceeding to terminate her parental rights prior to the petition; and second, that the family court’s finding of abandonment was not supported by clear and convincing evidence. The Court granted discretionary review.

As to the first issue, the Court offered a detailed analysis of the intersectionality between KRS Chapter 625, which governs involuntary termination proceedings, and KRS 199, which governs adoptions. While KRS 199.500 demands prior parental termination before consensual adoptions (specifically citing KRS Chapter 625), the Court highlighted that non-consensual adoptions under KRS 199.502 hold no such prerequisite. Noting that the Cabinet is not inherently a required party in KRS 199 adoption matters, the Court found KRS 199.502 was a proper avenue for adoption proceedings initiated by a private party that result in the termination of parental rights. Moving on to the Mother’s second point, the Court found that the family court’s findings were supported by clear and convincing evidence. KRS 199.502(1) allows non-consensual adoption if one of nine conditions exists with respect to the child, with subsection (a) listing “[t]hat the parent has abandoned the child for a period of not less than ninety (90) days.” The family court found that between November 2014 to November 2015, the Mother w failed to have any contact with the Child, despite being out of prison and possessing visitation rights. The Court found the evidence on the record as a whole clearly and convincingly supported the family court’s abandonment finding. Accordingly, the Court affirmed the Court of Appeals decision.

In a thorough dissent, Justice Lambert objected to such a reading of KRS 199.502, deeming it a “constitutional end-run created by a statutory loophole.” Emphasizing the importance of parental rights, Justice Lambert found the majority holding allows a private party to strip a natural parents’ constitutional right away without due process. As a result, the dissent implored that because this case concerned a matter of constitutional construction or interpretation, it should have been reviewed de novo and taken as an opportunity to “recognize and call out statutory gaps and the constitutional deficits.” The majority, addressing these concerns, stated that the dissent failed to identify how those protections allotted to natural parents already are constitutionally deficient. Likewise, the majority recognized that the Mother did not raise any constitutional objections in her request for review, and that the “Court [would] not develop arguments on behalf of the parties.”

K. Spencer Pierson

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Kenton Family Court

This decision focused on D.H. (father) and G.P. (mother), the parents of three children. Dating back to 2008, the Cabinet for Health and Family Services (the “Cabinet”) had been involved in matters relating to both parties based on concerns of substance abuse and domestic violence. Similar incidents continued to arise, with both parents through the years stipulating to substance abuse and neglect of the children. During this time, the children were placed with various relatives, but ultimately entered foster placement in July 2019. In August 2020, the Cabinet filed a petition against both parents to involuntarily terminate their parental rights to each of the children. A bench trial was held on the matter on March 18, 2021, with the family court entering judgments to terminate both parties’ parental rights on June 11, 2021. D.H. appealed the judgements.

The Court of Appeals reviewed the family court’s findings under the lens of “clearly erroneous, “only disturbing said findings if there were “no substantial evidence in the record to support them.” The Court, evaluating KRS 625.090 and the requirements it set for involuntary termination of parental rights, found that the family court entered extensive findings of fact, followed by conclusions of law on each of the mandatory statutory elements. Furthermore, the Court found no error in the family court entering its judgment on the matter nearly two months after the hearing and outside the 30-day time period set out in KRS 625.090(6). The Court found that this time limit did not impose a “jurisdictional barrier for granting termination beyond the time limit” but was merely a means to “expedite permanency for children.” Though the Court did not approve of the delay, it concluded the error was harmless to the family court’s ultimate finding and did not violate D.H.’s substantial rights. Accordingly, the Court affirmed the family court’s decision to terminate the parents’ parental rights.

Digested by K. Spencer Pierson

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Mason Circuit Court

The Mother of two children, K.A.M.R. and K.N.R., filed petitions to involuntarily terminate the parental rights of each respective child’s father. Neither father had been involved in their child’s life for many years. Mother named the Cabinet for Health and Family Services (“the Cabinet”) as a party to the action. The relevant statute, KRS 625.090 specifically requires that the court find by clear and convincing evidence that the Cabinet “has filed a petition with the court pursuant to KRS 620.180” when assessing a petition for the involuntary termination of parental rights. The Cabinet stated no objections to Mother’s request and confirmed it had no prior history with any of the parents. Father of K.AM.R. filed a responsive pleading requesting the dismissal of Mother’s petition (father of K.N.R. never participated in the proceeding). The trial court focused whether the court had jurisdiction “where a parent petitions to terminate the parental rights of another parent when the child was never placed with the Cabinet and when a DNA action was never opened.” Ultimately, the trial court dismissed the action, finding that an essential element of the statute was not met, as the Cabinet had never filed any petition whatsoever for the parents involved. Mother filed a timely appeal.

Mother’s appeal was based on a claim that the disputed statute was unconstitutional, along with a claim that the trial court’s dismissal was based on an inaccurate interpretation of the statute. A failure on the part of the Mother to notify the Attorney General, therefore not complying with KRS 418.075, prevented the Court of Appeals from tackling the former issues; nonetheless, the Court was able to dissect the Mother’s latter claim, eventually concluding that the trial court made no error. Reviewing the trial court’s statutory application de novo, the Court found the statute’s text clear in stating the Cabinet’s petition was a necessary element for an involuntary termination of parental rights. While the Court noted the statute contained “admittedly confusing” portions, they found no legislative history to suggest that, as the Mother argued, the language in KRS 625.090 was adopted by mistake. Accordingly, the Court affirmed the trial court’s judgment.

Alongside the holding, concurring and dissenting opinions were filed. Judge Cetrulo concurred, but in result only. While the plain language of the statute bound the Court to its ultimate finding, the fact the statute created a “scenario where a parent who cared for their child without Cabinet involvement is more restricted in protecting his/her child than a parent who has been subject to Cabinet involvement and support” was illogical enough to raise skepticism as to whether that was truly the General Assembly’s intention. Nevertheless, Judge Cetrulo noted that this appeal was not the appropriate venue to remedy such a conflict.  Judge Jones’, agreeing the trial court’s interpretation of the statute allowed absurd scenarios, dissented. Highlighting the legislative history of KRS 625.090, Judge Jones concluded the intention of the Cabinet petition prong of the statute was supposed to be read in conjunction with KRS 620.180, and should only be required in those cases where “children [have been] committed to the cabinet as dependent, neglected, or abused and placed in foster family homes[.]” Seeing as the child at issue fell under neither of the aforementioned categories, Judge Jones stated that remanding the matter was the proper holding, as the petition was wrongfully dismissed by the trial court.

Digested by K. Spencer Pierson

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Barren Circuit Court

Questions Presented: Appellate Procedure. Children as Indispensable Parties in an Appeal from a Termination of Parental Rights. Notice to the Guardian Ad Litem. The issue is whether children are indispensable parties on appeal in a termination of parental rights case or whether notice to the guardian ad litem is sufficient to protect the children’s interest on appeal.

The issue in this case is whether there is substantial compliance with CR 73.03, which requires that a notice of appeal specify by name all appellants and appellees, where, although the children of the termination of parental rights case were not named as parties, the guardian ad litem received adequate notice of the appeal. The Supreme Court of Kentucky held that service of the notice of appeal upon a child’s guardian ad litem is sufficient to provide adequate notice to the child and to confer jurisdiction over that child to an appellate court. 73.02 only requires dismissal of an appeal if a party fails to timely file a notice of appeal, cross-appeal, or motion for discretionary review. Failure to comply with other rules relating to appeals or motions for discretionary review permit other sanctions up to and including dismissal of the appeal. The sanction imposed should bear some resemblance to the seriousness of the defect. Dismissal is not a proper remedy when no substantial harm or prejudice has resulted from the defect. The statutorily mandated appointment of a guardian ad litem for children at issue in a termination proceeding sufficiently protects their interests, as long as the guardian ad litem is served with the notice of appeal.

Digested by Nathan R. Hardymon

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Livingston Circuit Court

Questions Presented: Child Custody. Issues involve attempted adoptions of two children to terminate their biological father’s rights (without terminating their mother’s parental rights) as well as the applicability and viability of the parental “waiver” decision of Mullins v. Picklesimer, 317 S.W.3d 569 (Ky. 2010).

The issues decided by the Supreme Court of Kentucky in this opinion were: (1) whether a non-stepparent adoption that does not terminate the parental rights of both biological parents is violative of Kentucky’s adoption statutes, and (2) whether the doctrine of “partial waiver” of a biological parent’s superior custodial rights as established in Mullins v. Picklesimer is still viable in light of the federal legalization of same-sex marriage in Obergefell v. Hodges.

In this matter, Family Court terminated unknown fathers’ parental rights, did not terminate Mother’s parental rights, and permitted a non-stepparent to adopt Children. The Supreme Court held that because the adoptions orders did not terminate parental rights of both of the biological parents of Children, they are invalid. KRS 199.520(2) provides that “[u]pon granting an adoption, all legal relationship between the adopted child and the biological parents shall be terminated except the relationship of a biological parent who is the spouse of an adoptive parent.” It is clear that both biological parents’ rights must be terminated, except in the case of a stepparent.

The Supreme Court then held that Mullins v. Picklesimer is still good law post-Obergefell v. Hodges. The Court made it clear that holding in Picklesimer permitting the doctrine of partial waiver of custodial rights was in no way predicated upon the fact that the case involved a same-sex couple. It disagreed with the Court of Appeals that the legalization of same-sex marriage in any way affected the holding in Picklesimer.

Digested by Nathan R. Hardymon

The post Both Parents’ Rights Must Be Terminated Prior to Adoption; Doctrine of Partial Waiver of Custodial Rights Still Good Law Post-Obergefell – Published Opinion from Supreme Court of Ky. appeared first on Goldberg Simpson - Family Law Group.

Spencer Circuit Court

After the Cabinet for Health and Family Services (“the Cabinet”) petitioned to terminate Mother’s parental rights, Family Court held a hearing, ultimately terminating Mother’s parental rights. Mother appealed.

The Court of Appeals held that there was no clear and convincing evidence that the children were abused or neglected. The petition was based on a single incident of the children being exposed to drug use in a shed occupied by Maternal Grandmother in which Mother was allegedly involved. There was no evidence that Mother failed to attend to the children’s need or subjected them to abuse. Although she stipulated to neglect based on initial positive drug screens, she submitted to more than 50 drug screens throughout the matter, almost all of which were negative. Furthermore, an assessment from Centerstone stated that she did not meet the criteria for substance use diagnosis or treatment.

The Court of Appeals also held that the Cabinet failed to provide reasonable efforts to reunite the family. Her case plan requirements did not allow Mother to have any reasonable prospect of satisfactory completion given her circumstances. Mother was determined to be indigent, then was required to refrain from using illegal substances, call for drug screen protocol outside her home county at her expense, attend supervised visitation at $50 per visit, participate in substance misuse and mental health assessments, complete a parenting class, obtain stability by having appropriate employment, housing, and transportation, and pay child support based upon imputed income. Mother made significant efforts, including submitting to more than 50 drug screens at a total cost to her of $1,675.00; completing the required assessments at Centerstone; paying, as she was able due to indigency and unemployment, child support and providing clothes and gifts for the children at the supervised visitations; paying $50 per supervised visit to exercise her limited opportunity to visit her children at a facility located outside her home county; ensuring that Maternal Grandmother, whom the Cabinet identified as the source of Mother’s drug problem, no longer resided at the home and eliminating all contact with Maternal Grandmother; and attempting to obtain a driver’s license. The actions did not evince a settled purpose to forego all parental duties and relinquish all parental claims to the children. Mother made reasonable efforts to reunify her family, but the case plan put unreasonable obstacles in her way.

Finally, the Court of Appeals held that Mother was deprived of due process where Family Court could not hear or understand her in a Zoom hearing. The Court of Appeals reversed Family Court’s judgment terminating Mother’s parental rights with instructions to dismiss the Cabinet’s petition.

Digested by Nathan R. Hardymon

The post Petition to Terminate Parental Rights Dismissed for Lack of Abuse or Neglect, Reasonable Efforts to Reunite the Family, and Due Process – Published Opinion from Ky. Court of Appeals appeared first on Goldberg Simpson - Family Law Group.

The recent Kentucky Supreme Court case of Cabinet for Health and Family Services v. H.L.O. provides a great example of how complicated these cases can be. In that case, a mother gave birth to a child and both the child and the mother tested positive for drugs immediately after the birth. The child was removed from the mother, who was then given a case plan to work in order to have her child returned to her. Throughout the case, the mother struggled with continued drug use. Eventually, the court did what is called a “goal change.” This is when the court changes the goal of the case from “return to parent” to having the child adopted after that parent’s rights are terminated.

The Cabinet for Health and Family Services filed a petition to terminate the mother’s rights. The Cabinet presented evidence that it took the mother a very long time to work her plan and continued to struggle in various ways. The mother was able to present evidence that she had made significant progress in her sobriety and living situation. Also, the mother maintained custody of two prior born children and was able to care for them. In the end, the family court terminated her parental rights. The Supreme Court agreed.

In termination cases, the court must follow a very strict set of laws that dictate when a termination is proper. Failure to adhere to this procedure would provide a basis to have a termination reversed on appeal. The laws on the subject are very complicated and there are many ways an error could occur. An experienced attorney is able to keep a close eye on whether the Cabinet and the court have made any errors that would be beneficial to the client’s case. Also, the facts in these cases can sometimes lead to situations where it is a close call for a court to decide whether to terminate or not. A skilled attorney can highlight the positive aspects of your case and fight back against the Cabinet’s allegations in order to maximize your chances of success.

It is also worth noting that termination of parental rights can have an impact on future cases. Specifically, if a parent has an involuntary termination of parental rights in a past case, it makes it easier for the rights to a future child to be terminated. In circumstances where a parent has little to no chance of success, the parent should discuss with their attorney the benefits of voluntarily terminating his or her parental rights to prevent this.

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