Arkansas Code Annotated

Ark. Code Ann. § 9-27-337 (2026)

Six-month reviews required

✓ current as of May 2026
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    1. The court shall review every case of dependency-neglect or families in need of services when:
      1. A juvenile is placed by the court in the custody of the Department of Human Services or in another out-of-home placement until there is a permanent order of custody, guardianship, or other permanent placement for the juvenile; or
      2. A juvenile is returned to the parent from whom the child was removed, another fit parent, guardian, or custodian and the court has not discontinued orders for family services.
      1. The first six-month review shall be held no later than six (6) months from the date of the original out-of-home placement of the child and shall be scheduled by the court following the adjudication and disposition hearing.
      2. It shall be reviewed every six (6) months thereafter until permanency is achieved.
  1. The court may require these cases to be reviewed prior to the sixth-month review hearing, and the court shall announce the date, time, and place of the hearing.
  2. At any time during the pendency of any case of dependency-neglect or families in need of services in which an out-of-home placement has occurred, any party may request the court to review the case, and the party requesting the hearing shall provide reasonable notice to all parties.
  3. At any time during the course of a case, the department, the attorney ad litem, or the court can request a hearing on whether or not reunification services should be terminated pursuant to § 9-27-327(a)(2).
    1. In each case in which a juvenile has been placed in an out-of-home placement, the court shall conduct a hearing to review the case sufficiently to determine the future status of the juvenile based upon the best interest of the juvenile.
      1. The court shall determine and include in its orders the following:
        1. Whether the case plan, services, and placement meet the special needs and best interest of the juvenile, with the juvenile's health, safety, and educational needs specifically addressed;
        2. Whether the state has made reasonable efforts to provide family services;
        3. Whether the parent or parents or person from whom custody was removed has demonstrated progress toward the goals of the case plan and whether completion of the goals has benefited the parent in remedying the issues that prevent the safe return of the juvenile;
        4. Whether the case plan is moving toward an appropriate permanency plan under § 9-27-338 for the juvenile;
        5. Whether the visitation plan is appropriate for the juvenile, the parent or parents, and any siblings, if separated; and
          1. Whether the juvenile should be returned to his or her parent or parents and whether or not the juvenile's health and safety can be protected by his or her parent or parents if returned home, either permanently or for a trial placement.
          2. At any time the court determines that the health and safety of the child can be adequately protected and it is in the best interest of the child, the court shall return the child to a parent or parents from whom custody was removed.
        1. The court may order any studies, evaluations, or post-disposition reports, if needed.
        2. All studies, evaluations, or post-disposition reports shall be provided in writing to all parties and counsel at least two (2) days before the review hearing.
        3. All parties shall be given a fair opportunity to controvert any part of a study, evaluation, or post-disposition report.
      1. In making its findings, the court shall consider the following:
        1. The extent of compliance with the case plan, including without limitation a review of the department's care for the health, safety, and education of the juvenile while he or she has been in an out-of-home placement;
        2. The extent of progress that has been made toward alleviating or mitigating the causes of the out-of-home placement;
        3. Whether the juvenile should be returned to his or her parent or parents and whether or not the juvenile's health and safety can be protected by his or her parent or parents if returned home; and
        4. An appropriate permanency plan under § 9-27-338 for the juvenile, including concurrent planning.
      2. Incompletion of the case plan under subdivision (e)(3)(A)(i) of this section is an insufficient reason by itself to deny the juvenile's return to the family home.
  4. Each six-month review hearing shall be completed, and the written order under subsection (e) of this section shall be filed by the court or by a party or a party's attorney as designated by the court and distributed to the parties within thirty (30) days of the date of the hearing or before the next hearing, whichever is sooner.

History. Acts 1989, No. 273, § 36; 1995, No. 404, § 1; 1995, No. 533, § 12; 1995, No. 1337, § 8; 1997, No. 1227, § 11; 1999, No. 401, § 12; 2001, No. 987, § 5; 2001, No. 1503, § 11; 2005, No. 1191, § 3; 2005, No. 1990, § 17; 2007, No. 587, § 20; 2013, No. 490, § 1; 2017, No. 701, § 4.

Amendments. The 2005 amendment by No. 1191 rewrote this section.

The 2005 amendment by No. 1990 added (e)(1)(B)(ii)(a)-(c).

The 2007 amendment inserted “not” in (a)(1)(B).

The 2013 amendment inserted “from whom the child was removed, another fit parent” in (a)(1)(B); added “and shall be scheduled by the court following the adjudication and disposition hearing” at the end of (a)(2)(A); rewrote (b); and added “and the party requesting the hearing shall provide reasonable notice to all parties” at the end of (c).

The 2017 amendment redesignated former (e)(1) and (2) as (e) and (f) and redesignated the subdivisions within present (e) accordingly; inserted (e)(2)(A)(iii) and added (e)(2)(A)(vi); added (e)(3)(B); substituted “the written order under subsection (e) of this section” for “a written order” in (f); and made stylistic changes.

Case Notes

Applicability.

Once the juvenile court took jurisdiction of a matter as a dependent-neglect case, the Juvenile Code provisions became applicable; that being so, the juvenile court was obliged to provide for periodic reviews under this section and § 9-27-338. Nance v. Ark. Dep't of Human Servs., 316 Ark. 43, 870 S.W.2d 721 (1994).

There is no authority for a juvenile court to dismiss dependent-neglect proceedings when the parties all comply with the case plan and reasonable efforts are being made by all concerned; periodic review should be continued, regardless of such compliance. Nance v. Ark. Dep't of Human Servs., 316 Ark. 43, 870 S.W.2d 721 (1994).

Attorney's Fees.

Order requiring the Department of Health and Human Services to pay for an attorney for a child in its custody who had been accused of sexual misconduct was upheld pursuant to § 9-27-334; providing the child with an attorney, in order to keep the child off the sex offender list, would greatly assist in the child's adoption. Ark. Dep't of Health & Human Servs. v. C.M., 100 Ark. App. 414, 269 S.W.3d 387 (2007).

Hearing Required.

Circuit court clearly erred in denying a father's motion to place a child with the child's paternal uncle and the uncle's wife, who were stationed in Germany, where a home study did not show anything suggesting that placement with the relatives was not in the child's best interests or that the relatives were unfit, it failed to conduct a mandatory review hearing required by this section, and thus, it had inappropriately ignored the statutory preference for relative placement in § 9-27-355(b)(1) and § 9-28-105. Ellis v. Ark. Dep't of Human Servs., 2016 Ark. 441, 505 S.W.3d 678 (2016).

Notes of Decisions
Cited in 14 cases (2 in the last 5 years), 1993–2026 · leading case: Martin v. Arkansas Dep't of Human Servs., 2017 Ark. 115 (Ark. 2017).
Martin v. Arkansas Dep't of Human Servs., 2017 Ark. 115 (Ark. 2017). · cites it 6× “Ark. Code Ann. § 9-27-337 (a)(1)(A) (Supp.”
Ellis v. Arkansas Dep't of Human Servs., 2016 Ark. 441 (Ark. 2016). · cites it 8× “Patricia Herring, the ADHS caseworker assigned to the case, testified that ADHS 1 Arkansas Code Annotated section 9-27-337 (Repl. 2015) provides, in part, as follows: (a)(1) The court shall review every case of dependency-neglect or families in need of services when: (A) A…”
In Re Final Rules for Acceptance of Records on Appeal in Elec. Format & Elimination of the Abstracting & Addendum Requirements, 2020 Ark. 421 (Ark. 2020). · cites it 2× “Rule 54(b) entered at the review hearing in accordance with Ark. Code Ann. §9-27-337 and the review order entered on is being appealed.”
Arkansas Dep't of Health & Human Servs. v. C.M., 269 S.W.3d 387 (Ark. Ct. App. 2007). · cites it 8× “Ark. Code Ann. § 9-27-337 (b)(l)(A). The court shall determine and shall include in its orders the following: whether the case plan, services, and placement meet the special needs and best interest of the juvenile, with the juvenile’s health and safety specifically addressed;…”
Suster v. Arkansas Dep't of Human Servs., 858 S.W.2d 122 (Ark. 1993). · cites it 2× “After conducting several periodic reviews as mandated by Ark. Code Ann. § 9-27-337 (Repl. 1991), the court entertained a petition on September 17,1991 to terminate Lori Hughes Cook’s parental rights.”
Arkansas Dep't of Human Servs. v. Southerland, 985 S.W.2d 336 (Ark. Ct. App. 1999). · cites it 4× “section 9-27-337 (b)(1) (Repl. 1998), the juvenile court shall determine and shall include in its orders whether the case plan, services, and placement meet the special needs and best interests of the juvenile and whether the state has made reasonable efforts to provide family…”
Hathcock v. Arkansas Dep't of Human Servs., 69 S.W.3d 6 (Ark. 2002). · cites it 2× “See Ark. Code Ann. §§ 9-27-337 and -338 (Repl.”
Burks v. Arkansas Dep't of Human Servs., 61 S.W.3d 184 (Ark. Ct. App. 2001). · cites it 2× “I recognize that both the trial court and the department are hurried by the legal requirements as to time imposed by Ark. Code Ann. § 9-27-337 & -338 (Supp. 1999), as well as the practical consideration that a child neither returned to the home nor given a new permanent home…”
Avery v. State, 844 S.W.2d 364 (Ark. 1993). · cites it 2× “See Ark. Code Ann. §§ 9-27-337 (7), 9-2-339(e) (1991).”
Nance v. Arkansas Dep't of Human Servs., 870 S.W.2d 721 (Ark. 1994). “§ § 9-27-337 and 9-27-338 (Repl. 1993). The record reflects the juvenile court did conduct hearings, but when it concluded its final hearing it merely found Mary Lila needed stability and her best interests would be served by transferring (continuing) custody with her father.”
Ponder v. Arkansas Dep't of Human Servs., 2016 Ark. App. 61 (Ark. Ct. App. 2016). · cites it 4× “2013), the court shall review'every case of dependency-neglect 'when: (a)(1)(A) A juvenile is placed by the court in the custody of [DHS] or in anothei* out-of-home placement until 'there is a permanent order of custody [[Image here]] (e)(1)(A) In each case in which a juvenile…”
Christine Rodriguez v. Arkansas Dep't of Human Servs. & Minor Child., 2024 Ark. App. 469 (Ark. Ct. App. 2024). · cites it 2× “See Ark. Code Ann. § 9-27-337 (Supp. 2023). We are therefore unconvinced that Rodriguez’s argument, premised as it is on section 9-27-327, is well founded.”
— Ark. Code Ann. § 9-27-337(a)(l)(A) — 1 case
Ponder v. Arkansas Dep't of Human Servs., 2016 Ark. App. 61 (Ark. Ct. App. 2016). “2013), the court shall review'every case of dependency-neglect 'when: (a)(1)(A) A juvenile is placed by the court in the custody of [DHS] or in anothei* out-of-home placement until 'there is a permanent order of custody [[Image here]] (e)(1)(A) In each case in which a juvenile…”
— Ark. Code Ann. § 9-27-337(b)(1) — 1 case
Arkansas Dep't of Human Servs. v. Southerland, 985 S.W.2d 336 (Ark. Ct. App. 1999). “section 9-27-337 (b)(1) (Repl. 1998), the juvenile court shall determine and shall include in its orders whether the case plan, services, and placement meet the special needs and best interests of the juvenile and whether the state has made reasonable efforts to provide family…”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.