Linda Camarillo-Cox v. Arkansas Department of Human Services

Summary

The Supreme Court of Arkansas affirmed the Benton County Circuit Court's order terminating Linda Camarillo-Cox's parental rights to her four children and reversed the court of appeals, which had reversed the termination for lack of clear and convincing evidence. Reviewing under the clearly erroneous standard, the court held that clear and convincing evidence supported all three statutory grounds: the children had been out of the home over sixteen months despite meaningful DHS efforts, the mother failed to provide meaningful support and contact, and she manifested incapacity or indifference to remedying the conditions causing removal. Consistent with Jefferson and Trout, the court reasoned that the mother's compliance with her case plan, achieved only in the months immediately before the termination hearing, did not outweigh her history of instability. No separate opinions were filed.