10 Arkansas opinions name it 1 courts 2018–2025 7 in the last five years
The cases below were cited by Arkansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Furnish v. Arkansas Department of Human Servicesgreen2 sentences2025See Furnish, 2017 Ark. 2025See Furnish, 2017 Ark. | 1 | 1 |
Nicholas Myers and Myrtle Myers v. Arkansas Department of Human Services and Minor Childgreen1 sentence2025App. 46, at 14 , 660 S.W.3d 357, 368 (affirming subsequent-factors ground where the mother was ordered to complete a myriad of tasks at the beginning of the case and waited until the month before the TPR hearing to begin). | 1 | 1 |
Kacie Scott v. Arkansas Department of Human Services and Minor Childrengreen2 sentences2023App. 200, at 4 , 624 S.W.3d at 700 (finding that the parent’s argument regarding family placement was not preserved because the specific argument was not made to the circuit court at the termination hearing and thus precluded this court from considering it 1 We are unaware whether a relative-placement argument was made prior to the TPR hearing because those hearings and their transcripts are not part of this record. 8 on appeal); Darnell v. Ark. 2023App. 200, at 4 , 624 S.W.3d at 700 (finding that the parent’s argument regarding family placement was not preserved because the specific argument was not made to the circuit court at the termination hearing and thus precluded this court from considering it 1 We are unaware whether a relative-placement argument was made prior to the TPR hearing because those hearings and their transcripts are not part of this record. 8 on appeal); Darnell v. Ark. | 1 | 1 |
Ashley Rocha & Christopher Rocha v. Arkansas Department of Human Services and Minor Childrengreen2 sentences2023App. 454, at 15 , 637 S.W.3d 299, 309 (failure to raise sibling-separation argument at the TPR hearing). 2023App. 454, at 15 , 637 S.W.3d 299, 309 (failure to raise sibling-separation argument at the TPR hearing). | 1 | 1 |
Bean v. Arkansas Department of Human Servicesgreen2 sentences2019App. 77, at 38 , 513 S.W.3d 859, 876 (“[E]vidence presented at a TPR hearing that parents have made overtures toward participating in the 13 case plan while TPR is looming is an insufficient reason not to terminate parental rights.”); see also Gann v. Ark. 2019App. 77, at 38 , 513 S.W.3d 859, 876 (“[E]vidence presented at a TPR hearing that parents have made overtures toward participating in the 13 case plan while TPR is looming is an insufficient reason not to terminate parental rights.”); see also Gann v. Ark. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Arkansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Katiana Cole v. Arkansas Department of Human Services and Minor Children
green
2 sentences2024App. 481 , at 11–12, 611 S.W.3d 218 , 224–25 (noting that we are precluded from review where the appellant did not make the less restrictive relative-placement argument she later made on appeal to the circuit court at the TPR hearing). 2024App. 481 , at 11–12, 611 S.W.3d 218 , 224–25 (noting that we are precluded from review where the appellant did not make the less restrictive relative-placement argument she later made on appeal to the circuit court at the TPR hearing). | 1 | 2024–2024 |
Langston v. Ark. Dep't of Human Servs.
neutral
2 sentences2022Servs., 2019 Ark. 152 , 574 S.W.3d 138 (holding that even when constitutional issues are presented in a TPR hearing, these objections will be waived unless made in a timely fashion to the circuit court); Taylor v. Ark. 2022Servs., 2019 Ark. 152 , 574 S.W.3d 138 (holding that even when constitutional issues are presented in a TPR hearing, these objections will be waived unless made in a timely fashion to the circuit court); Taylor v. Ark. | 1 | 2022–2022 |
Solee v. Arkansas Department of Human Services
green
2 sentences2021Solee, 2017 Ark. 2021Solee, 2017 Ark. | 1 | 2021–2021 |
Hendrix v. Winter
green
2 sentences2021App. 725, at 5 , 478 16 S.W.3d 272, 276 , we held that the trial court clearly erred in its findings where there was no evidence introduced at the TPR hearing regarding the adoptability of the child, and the trial court made no finding that the absence of evidence of adoptability made “no legal difference” to the ultimate decision of what was in the child’s best interest. 2021App. 725, at 5 , 478 16 S.W.3d 272, 276 , we held that the trial court clearly erred in its findings where there was no evidence introduced at the TPR hearing regarding the adoptability of the child, and the trial court made no finding that the absence of evidence of adoptability made “no legal difference” to the ultimate decision of what was in the child’s best interest. | 1 | 2021–2021 |
Franklin Peterson and Rachel Peterson v. Arkansas Department of Human Services and Minor Child
green
2 sentences2020App. 75, at 11 , 595 S.W.3d 38 , 44–45, which presented a similar situation: Although Franklin may have raised a services argument at the TPR hearing, he failed to challenge any of the circuit court’s prior reasonable- efforts findings, and he failed to request any of the specific services that he now claims were necessary to remedy the cause of removal; therefore, he has waived any services argument on appeal. 2020App. 75, at 11 , 595 S.W.3d 38 , 44–45, which presented a similar situation: Although Franklin may have raised a services argument at the TPR hearing, he failed to challenge any of the circuit court’s prior reasonable- efforts findings, and he failed to request any of the specific services that he now claims were necessary to remedy the cause of removal; therefore, he has waived any services argument on appeal. | 1 | 2020–2020 |
Miller v. Arkansas Department of Human Services
green
2 sentences2018Because a parent's past behavior may be considered as a sign of future behavior, see Miller , 2017 Ark. 2018Because a parent's past behavior may be considered as a sign of future behavior, see Miller , 2017 Ark. | 1 | 2018–2018 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.