Hudson v. Ark. Dep't of Human Servs., 2017 Ark. App. 629

On July 16–21, 2016, DHS removed 3‑year‑old H.G. after she was found with second‑degree burns and appellant Joanna Hudson tested positive for methamphetamine, THC, amphetamines, and benzodiazepines; an emergency removal order followed.
DHS had prior true findings of inadequate supervision concerning Hudson (2001 and 2013); in 2013 Hudson had been arrested for public intoxication and methamphetamine possession.
H.G. was adjudicated dependent‑neglected on November 3, 2016; DHS filed a termination petition (Oct. 2016), later amended (Mar. 2017) to add abandonment, substantial criminal‑sentence, and aggravated‑circumstances grounds.
At the termination hearing the court left the record open; Hudson, incarcerated at ADC and later serving a five‑year sentence, opposed termination and requested visitation but had little post‑removal contact and limited engagement with the case plan.
The record included a forensic‑interviewer’s testimony and DHS caseworker confirmation that H.G. credibly disclosed sexual abuse by Hudson; DHS also presented evidence of ongoing substance abuse and Hudson’s inability to provide timely permanency.
On May 4, 2017, the circuit court terminated Hudson’s parental rights based on subsequent‑factors, aggravated circumstances (including chronic and sexual abuse), and her lengthy criminal sentence, and found termination was in H.G.’s best interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was in the child’s best interest	Hudson: DHS failed to prove potential harm or lack of case‑plan compliance; testimony about noncompliance was speculative	DHS: Best interest shown by credible sexual‑abuse disclosure, past substance abuse, lack of contact, and Hudson’s incarceration preventing timely reunification	Court: Affirmed—clear and convincing evidence termination was in H.G.’s best interest

None (opinion relies on Arkansas appellate slip opinions without official reporter citations)