Tiffany Amelia Dinkins v. Arkansas Department of Human Services

Summary

The Supreme Court of Arkansas granted DHS's petition for review and reversed the court of appeals, which had overturned a chancery court's termination of Tiffany Dinkins's parental rights to three children for insufficiency of the evidence. Applying the clearly erroneous standard with deference to the chancellor's credibility determinations, the court held clear and convincing evidence supported termination under Ark. Code Ann. § 9-27-341(b)(3)(B)(i)(a): the children had been adjudicated dependent-neglected and out of the home over two years and four months despite DHS's meaningful rehabilitation efforts, and Dinkins failed to maintain a sanitary home, hold steady employment, or end the abuse. The court agreed the chancellor erred in adding a failure-to-provide-material-support ground, but affirmed anyway because a chancellor's proper result may stand despite an incorrect reason.