best-interest analysis in Arkansas

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2020Id.

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2012Troxel v. Granville, 530 U.S. 57 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000) (plurality opinion) (finding statute that allowed visitation by third parties based solely on a best-interest standard unconstitutional); Linder v. Linder, 348 Ark. 322, 342 , 72 S.W.3d 841, 851 (2002).

2012Troxel v. Granville, 530 U.S. 57 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000) (plurality opinion) (finding statute that allowed visitation by third parties based solely on a best-interest standard unconstitutional); Linder v. Linder, 348 Ark. 322, 342 , 72 S.W.3d 841, 851 (2002).

2021Id.

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2017Id., 314 S.W.3d at 728 .

2009Id.

2026App. 725 , 478 S.W.3d 272 (evidence of a parent’s history with the child’s siblings and DHS may be relevant to the best-interest analysis).

2016Brown, 2015 Ark.App. 725, at 5 , 478 S.W.3d at 275-76 .

2024App. 440, at 10 , 376 S.W.3d 489, 494 ; see also McCoy v. Kincade, 2015 Ark. 389, at 5 , 473 S.W.3d 8, 11 . 11 Kristen next argues that the court erred in failing to conduct a best-interest analysis.

2024App. 440, at 10 , 376 S.W.3d 489, 494 ; see also McCoy v. Kincade, 2015 Ark. 389, at 5 , 473 S.W.3d 8, 11 . 11 Kristen next argues that the court erred in failing to conduct a best-interest analysis.

2024See Bunch, supra; Cranford, supra. Each of those cases resulted in a reversal of the circuit court’s TPR order and demonstrate that TPR is not always necessary, especially given that the public interest behind TPR is to ensure that children will obtain greater stability and permanence and not languish in foster care indefinitely—a circumstance Cassandra maintains her children did not face.

2020A mere conclusory statement without convincing argument or 20 Id. 21 Id. 22 Id. 12 authority is not effective to raise a point on appeal. 23 Furthermore, Chavez did not introduce evidence to the circuit court regarding the relationship that the twins shared with their siblings.

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2019Id.

2021Id. at 4, 529 S.W.3d at 278 .

2019Id. at 4, 529 S.W.3d at 278 .

2021See also In re Adoption of J.P., 2011 Ark. 535, at 19 , 385 S.W.3d 266, 278 ; Hollis v. Hollis, 2015 Ark.

2021App. 441, at 10 , 468 S.W.3d 316 (affirming trial court order that considered relationship between the child and child’s extend family as part of a best-interest analysis).

2019App. 131 , 456 S.W.3d 383 , Fisher argues that this is contrary to Arkansas law because without a conclusive decision on the relative-placement issue, it would be impossible for the circuit court to conduct a full best-interest analysis.

2019App. 131 , 456 S.W.3d 383 , Joslin contends that the best-interest analysis cannot be addressed without fully considering the relative-placement issue.

2017Id.

2016Ark.Code Ann. § 9 — 27—341(b)(3)(B), (b)(3)(A) (Repl.2015); Harbin, supra. We review termination-of-parental-rights cases de novo.

2013Although McBride testified that she could provide a safe home for J.M., there was evidence that drugs were being sold from her 6 Cite as 2013 Ark.

2013Although McBride testified that she could provide a safe home for J.M., there was evidence that drugs were being sold from her 6 Cite as 2013 Ark.

2026App. 606 , 344 S.W.3d 670 (failure to obtain stable income or housing is relevant to the best-interest analysis). 7 Mason has filed her own points, arguing that the court’s decision should be reversed.

2026App. 229 , 687 S.W.3d 584 (stating that if the threshold requirement of a material change in circumstances is not met, the court does not proceed to a best-interest analysis).

2025The majority does not seem bothered by the lack of attention to this most important issue and instead cites Emis v. Emis, 2017 Ark.

2023Id.

2023App. 459 , 503 S.W.3d 842 . 7 child.16 The first step requires proof of one or more statutory grounds for termination; the second step, the best-interest analysis, includes consideration of the likelihood that the juvenile will be adopted and of the potential harm caused by returning custody of the child to the parent.17 Each of these requires proof by clear and convincing evidence, which is the degree of proof that will produce in the finder of fact a firm conviction regarding the allegation sought to be established.18 One ground relied on by the circuit court when terminating appellant’s par

2022Servs., 360 Ark. 340 , 201 S.W.3d 391 (2005). 10 The best-interest standard also includes consideration of the following two factors: (1) the child’s likelihood of adoption; and (2) the potential for harm from returning the children to the parents’ custody.

2022Servs., 360 Ark. 340 , 201 S.W.3d 391 (2005). 10 The best-interest standard also includes consideration of the following two factors: (1) the child’s likelihood of adoption; and (2) the potential for harm from returning the children to the parents’ custody.

2022Servs., 2015 Ark. 356 . 10 Termination of parental rights is a two-step process requiring a determination that the parent is unfit and that termination is in the best interest of the child. 7 The first step requires proof of one or more statutory grounds for termination; the second step, the best- interest analysis, includes consideration of the likelihood that the child will be adopted and of the potential harm caused by returning custody of the child to the parent. 8 Each of these requires proof by clear and convincing evidence, which is the degree of proof that will produce in the finder of

2022Cox, 2022 Ark.

2021Qualheim v. Roush, 2019 Ark.

2021Id.