In the Interest of E. N. R., 323 Ga. App. 815

Department filed deprivation complaints on August 23, 2012 for four children after a condemned home and alleged parental noncooperation.
Shelter care order issued the same day, with 72-hour hearing later finding probable cause to believe deprivation existed.
Deprivation petition filed August 31, 2012; initial hearings occurred September 10 and September 17, 2012, with progress to December for a full adjudicatory hearing.
December 17, 2012 final hearing resulted in an order adopting prior findings and concluding the children were deprived due to parental unfitness and low functioning.
The court found the parents loved their children but could not meet daily basic care, education, or financial needs; mental/financial incapacity supported deprivation.
September 2012 order and subsequent records relied on evidence including psychological evaluations showing cognitive limitations of both parents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports deprivation for parental unfitness.	Appellants contend evidence insufficient to prove deprivation.	Department argues low functioning and incapacity show deprivation at present.	Yes; sufficient clear and convincing evidence of deprivation.
Whether the deprivation finding was properly grounded in prior records.	Appellants challenge use of prior proceedings to justify current deprivation.	Department relies on judicial notice of the record as a whole, including prior findings.	Yes; court properly took judicial notice and relied on prior record.
Whether evidence of financial incapacity supports deprivation.	Appellants argue financials were not enough to deprive.	Department presented financial inability as rendering continued home placement contrary to welfare.	Yes; clear and convincing evidence of financial incapacity.
Whether the court properly considered psychological evaluations of parents.	Appellants may have challenged reliance on. mental function data.	Court properly admitted and relied on psychological assessments indicating low functioning.	Yes; evaluations supported deprivation findings.

In the Interest of G. S., 279 Ga. App. 89 (Ga. App. 2006) (reaffirming use of records and findings in deprivation context)
In the Interest of A. B., 285 Ga. App. 288 (Ga. App. 2007) (supporting judicial notice of prior deprivation orders and record)
In the Interest of L. B., 319 Ga. App. 173 (Ga. App. 2012) (discussing burden of showing depravity evidence and record-based review)