Christian-Holderfield v. Arkansas Department of Human Services, 2011 Ark. App. 534

Carroll County Circuit Court terminated parental rights of Rebecca Christian-Holderfield to A.G. and H.G. and of James Holderfield to F.H. on December 3, 2010.
DHS had previously removed A.G. and H.G. in July 2006 after safe-housing concerns and parental neglect; F.H. was later adjudicated dependent-neglected.
Children showed developmental delays; improper medical/dental care occurred during separations from parents.
Court ordered parenting classes, drug screens, housing stability, and other case-plan requirements; reunification efforts continued if conditions were met.
In 2009-2010, children improved in foster care but regressed during parental visits; in April 2010 permanency planning shifted to termination and adoption.
Trial court terminated parental rights after finding minimal compliance with case plan and best interests favored termination; appellate review focused on best-interest determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the termination in the children’s best interest?	Holderfields argue disruption from visitation caused anxiety; progress during sole custody shows potential for good parenting; therapy could fix issues.	Holderfields claim late compliance and behavioral improvements support return; not all factors show harm if reunification pursued with therapy.	Yes; termination in best interests supported by evidence of instability and potential harm in keeping custody.

Welch v. Ark. Dep’t of Human Servs., 2010 Ark. App. 798 (Ark. App. 2010) (de novo review; clear and convincing standard for best interests)
Carroll v. Ark Dep’t of Human Servs., 148 S.W.3d 780 (Ark. App. 2004) (best interests factors; adoption likelihood and health risks)