Holloway v. Arkansas Department of Human Services, 536 S.W.3d 642

E.W. was born October 19, 2015; DHS placed her on emergency hold and added her to an open dependency-neglect case already involving five half‑siblings of hers.
Robin (mother) had an extensive, long‑running DHS history dating back to 2007; her parental rights to five other children were involuntarily terminated shortly before E.W. was removed.
DHS filed for termination of parental rights to E.W.; multiple continuances followed and the termination hearing occurred March 2017.
Nathan (father) disclosed during a sex‑offender assessment a history of sexual activity with underage girls, a prior carnal‑abuse conviction (sister), multiple failures to register as a sex offender, and domestic‑battery convictions; he also had unstable housing/employment and missed counseling referrals.
The trial court found statutory grounds for termination as to Nathan (subsequent factors) and Robin (aggravated circumstance of prior termination to siblings) and concluded termination was in E.W.’s best interest (adoptability and risk of harm).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DHS proved the "subsequent factors" ground against Nathan	DHS: reassessment revealed new, dangerous facts (underage sexual contacts, multiple failures to register, domestic violence); Nathan failed to engage in offered counseling	Nathan: DHS did not adequately provide services; his sex‑offender level was later reduced and he sought reassessment	Court: Affirmed. Evidence showed subsequent factors arose, posed risk to child, and Nathan failed to remedy despite referrals.
Whether DHS proved aggravated‑circumstance ground against Robin (prior involuntary termination to a sibling)	DHS: Robin’s parental rights to five half‑siblings were involuntarily terminated months earlier, qualifying as aggravated circumstances	Robin: (implicit) challenge to applying prior sibling termination to justify termination here	Court: Affirmed. Prior involuntary termination of siblings satisfied aggravated‑circumstance ground.
Whether termination was in E.W.’s best interest (adoptability and potential harm)	DHS: E.W. was adoptable and would be harmed by returning to parents given parents’ histories and failures to remedy	Parents: contested sufficiency of evidence and adequacy of services	Court: Affirmed. Caseworker testimony and parents’ histories supported adoptability and risk analysis.

Reid v. Arkansas Dep’t of Human Servs., 380 S.W.3d 918 (Ark. 2011) (proof of one statutory ground is sufficient to support termination of parental rights)