Arkansas Code Annotated
Ark. Code Ann. § 9-27-329 (2026)
Disposition hearing
✓ current as of May 2026
- If the circuit court finds that the petition has been substantiated by the proof at the adjudication hearing, a disposition hearing shall be held for the court to enter orders consistent with the disposition alternatives.
- When a juvenile is held in detention after an adjudication hearing for delinquency pending a disposition hearing, the disposition hearing shall be held no more than fourteen (14) days following the adjudication hearing.
- In dependency-neglect proceedings, the disposition hearing may be held immediately following or concurrent with the adjudication hearing but in any event shall be held no more than fourteen (14) days following the adjudication hearing.
- In initially considering the disposition alternatives and at any subsequent hearing, the court shall give preference to the least restrictive disposition consistent with the best interests and welfare of the juvenile and the public.
- In dependency-neglect cases, a written disposition order shall be filed by the court, or by a party or party's attorney as designated by the court, within thirty (30) days of the date of the hearing or prior to the next hearing, whichever is sooner.
- At the disposition hearing, the court may admit into evidence any victim impact statements and studies or reports that have been ordered, even though they are not admissible at the adjudication hearing.
History. Acts 1989, No. 273, § 28; 1997, No. 1227, § 7; 1999, No. 401, § 8; 2001, No. 1503, § 8; 2003, No. 1809, § 5; 2009, No. 956, § 11; 2017, No. 701, § 3.
Amendments. The 2009 amendment deleted (c)(2)-(5) and redesignated subsection (c) accordingly.
The 2017 amendment, in (d), inserted “initially” and “and at any subsequent hearing”.
Cross References. No reunification hearing, § 9-27-365.
Case Notes
Appellate Review.
Trial court's disposition findings were not final and appealable under Ark. Sup. Ct. & Ct. App. R. 6-9(a)(1)(B) where the order did not include an Ark. R. Civ. P. 54(b) certificate. Walker v. Ark. Dep't of Human Servs., 2017 Ark. App. 627, 534 S.W.3d 184 (2017).
Placement With Relatives.
Circuit court did not clearly err when it determined that terminating the mother's parental rights was in the child's best interest where no relatives had been approved for placement at the time of the termination hearing, and the mother's aunt and uncle declined the court's initial offer of an Interstate Compact on the Placement of Children home study and did not seek placement until the termination hearing; however, adoption of the child was premature due to the unresolved paternity issue. Dominguez v. Ark. Dep't of Human Servs., 2020 Ark. App. 2, 592 S.W.3d 723 (2020).
Cited: Merritt v. Ark. Dep't of Human Servs., 2015 Ark. App. 552, 473 S.W.3d 31 (2015).
Notes of Decisions
Cited in 30
cases (17 in the last 5 years), 2000–2026 · leading case: Amorelle Best & John Best v. Arkansas Dep't of Human Servs. & Minor Child., 2020 Ark. App. 485 (Ark. Ct. App. 2020).
Amorelle Best & John Best v. Arkansas Dep't of Human Servs. & Minor Child., 2020 Ark. App. 485 (Ark. Ct. App. 2020). “A parent’s past behavior is often a good indicator of future behavior, and appellants’ behaviors over the course of the entire 21 case as outlined above do not show enough stability to render the circuit court’s finding that appellant posed a risk of potential harm to the…”
Dominguez v. Ark. Dep't of Human Servs., 2020 Ark. App. 2 (Ark. Ct. App. 2020). “She does not challenge the circuit court’s findings of adoptability or potential harm but instead argues that the evidence failed to demonstrate that termination was in CD’s best interest when a less restrictive alternative to termination was available.”
In Re Final Rules for Acceptance of Records on Appeal in Elec. Format & Elimination of the Abstracting & Addendum Requirements, 2020 Ark. 421 (Ark. 2020). “(date) ❑ The child/children were adjudicated dependent-neglected pursuant to Ark. Code Ann. §9-27-329 , and the adjudication order entered on is being appealed.”
Phillips v. Arkansas Dep't of Human Servs., 158 S.W.3d 691 (Ark. Ct. App. 2004). “MULLINS (DHS Counsel): Your Honor, under Section 9-27-329, which is a disposition hearing, if the Court determines that reunification services shall not be provided, the Court shall hold a permanency planning hearing within thirty days after the determination.”
Hunter v. State, 19 S.W.3d 607 (Ark. 2000). “Ark. Code Ann. § 9-27-329 , - 330, and -331 (Supp.”
L.C. v. State, 424 S.W.3d 887 (Ark. Ct. App. 2012). “contends that the trial court erred by committing her to DYS, arguing that the trial court failed to consider her best interests, the public welfare, and the least restrictive alternative as required by Ark.Code Ann. § 9-27-329(d) (Repl.2009). She points out that the intake…”
Amanda Borah & Steven Walls v. Arkansas Dep't of Human Servs. & Minor Child, 2020 Ark. App. 491 (Ark. Ct. App. 2020). “§ 9-27-329 (d) (Supp. 2019). Thus, the least restrictive alternative is a relevant inquiry 17 at a TPR hearing.”
Hardy v. Arkansas Dep't of Human Servs., 351 S.W.3d 182 (Ark. Ct. App. 2009). “Arguments on Appeal In her first point, Hardy argues that the circuit court erred by sua sponte ordering that no reunification services would be provided because Arkansas Code Annotated section 9-27-329 required at least fourteen days’ notice.”
Merritt v. Arkansas Dep't of Human Servs., 2015 Ark. App. 552 (Ark. Ct. App. 2015). “Ark. Code Ann. § 9-27-329 (d) (Repl. 2009).”
Samantha Cummings v. Arkansas Dep't of Human Servs. & Minor Child, 2021 Ark. App. 466 (Ark. Ct. App. 2021). “Arkansas Code Annotated section 9-27-329(d) 14 provides that in initially considering the disposition alternatives and at any subsequent hearing, the court shall give preference to the least restrictive disposition consistent with the best interest and welfare of the juvenile.”
Natayah Heggins v. Arkansas Dep't of Human Servs. & Minor Child, 2023 Ark. App. 45 (Ark. Ct. App. 2023). “” Ark. Code Ann. § 9-27-329 (a). “In dependency- neglect proceedings, the disposition hearing may be held immediately following or concurrent with the adjudication hearing .”
Walker v. Arkansas Dep't of Human Servs., 2017 Ark. App. 627 (Ark. Ct. App. 2017). “” However, she specifically argues that the children should have been returned to her custody while these services were being provided to the family as the “least restrictive disposition consistent with the best interests and welfare of the juvenile and the public.”
— Ark. Code Ann. § 9-27-329(a) — 1 case
Arkansas Dep't of Human Servs. v. Amberley Stephens, Amanda Mitchell, & Juniel Montelara, 2023 Ark. App. 405 (Ark. Ct. App. 2023).
— Ark. Code Ann. § 9-27-329(c)(2) — 1 case
Hardy v. Arkansas Dep't of Human Servs., 351 S.W.3d 182 (Ark. Ct. App. 2009). “Arguments on Appeal In her first point, Hardy argues that the circuit court erred by sua sponte ordering that no reunification services would be provided because Arkansas Code Annotated section 9-27-329 required at least fourteen days’ notice.”
— Ark. Code Ann. § 9-27-329(d) — 12 cases
Amorelle Best & John Best v. Arkansas Dep't of Human Servs. & Minor Child., 2020 Ark. App. 485 (Ark. Ct. App. 2020). “A parent’s past behavior is often a good indicator of future behavior, and appellants’ behaviors over the course of the entire 21 case as outlined above do not show enough stability to render the circuit court’s finding that appellant posed a risk of potential harm to the…”
Dominguez v. Ark. Dep't of Human Servs., 2020 Ark. App. 2 (Ark. Ct. App. 2020). “She does not challenge the circuit court’s findings of adoptability or potential harm but instead argues that the evidence failed to demonstrate that termination was in CD’s best interest when a less restrictive alternative to termination was available.”
L.C. v. State, 424 S.W.3d 887 (Ark. Ct. App. 2012). “contends that the trial court erred by committing her to DYS, arguing that the trial court failed to consider her best interests, the public welfare, and the least restrictive alternative as required by Ark.Code Ann. § 9-27-329(d) (Repl.2009). She points out that the intake…”
Samantha Cummings v. Arkansas Dep't of Human Servs. & Minor Child, 2021 Ark. App. 466 (Ark. Ct. App. 2021). “Arkansas Code Annotated section 9-27-329(d) 14 provides that in initially considering the disposition alternatives and at any subsequent hearing, the court shall give preference to the least restrictive disposition consistent with the best interest and welfare of the juvenile.”
Jessika Goforth v. Arkansas Dep't of Human Servs. & Minor Child., 2023 Ark. App. 233 (Ark. Ct. App. 2023).
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