In the Interest of C. B., 308 Ga. App. 158

Juvenile court found C.B., a minor, deprived after an evidentiary hearing.
Father appealed alleging admission of hearsay at the hearing and judicial notice of prior proceedings without sufficient notice.
DFACS caseworker testified about facts from a case file; father did not timely object, so error preservation fails.
Court took judicial notice of prior proceedings and orders; father had notice via consent to the form of the order and waived objection.
Evidence showed the mother posed a danger to C.B. with chronic substance abuse, criminal history, and prior child exposures; the father allowed contact with the mother despite an order to keep them apart; court inferred dishonesty and placed weight on the father’s testimony.
Court held the evidence was sufficient to sustain deprivation and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hearsay evidence admitted at hearing	Father contends DFACS caseworker testimony was hearsay	DFACS testimony lacked personal foundation; preserved error	No reversible error; objections not specified; preservation failure
Judicial notice of prior proceedings	Father argues lack of notice and opportunity to object	Written order shows consent and reference to prior orders	Adequate notice; waiver; no reversible error
Sufficiency of evidence to prove deprivation	Evidence showed danger from mother and lack of protection by father	Record inadequate to support deprivation	Evidence sufficient; deprivation sustained

In the Interest of A. K., 272 Ga. App. 429 (Ga. App. 2005) (preservation of objections to hearsay)
In the Interest of H. D. M., 241 Ga. App. 805 (Ga. App. 2000) (hearsay and foundation principles noted)
In the Interest of S. Y., 264 Ga. App. 623 (Ga. App. 2003) (courts may take judicial notice of prior proceedings)
In the Interest of M. N. H., 237 Ga. App. 471 (Ga. App. 1999) (judicial notice considerations)
In the Interest of J. A., 298 Ga. App. 11 (Ga. App. 2009) (judicial notice of prior proceedings)