In the Interest of T.B.L.T., 367 S.W.3d 663

On 27 April 2011, the Juvenile Office petitioned family court to exercise jurisdiction over minor T.B.L.T., born 6 October 2006, alleging lack of proper care, custody, or support.
A hearing occurred on 27 June 2011; Mother Elizabeth Lindsay appeared with counsel, while the Juvenile Office presented two witnesses about methamphetamine activity at the home.
Mother presented one witness, Alice Vanmeter, who testified the home was suitable and Mother did not live with her boyfriend.
The family court found T.B.L.T. in need of protection and asserted jurisdiction under § 211.031.1(1) and placed the child with the Children’s Division.
Mother appealed, challenging the evidence and the lack of explicit findings of fact to support jurisdiction.
On appeal, the court found the judgment deficient for failing to make required findings of fact under § 211.181.1 and remanded for a judgment compliant with that statute, with permission to receive additional evidence on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for jurisdiction	Lindsay argues evidence does not support jurisdiction.	State contends evidence shows neglect and necessity for protection.	Remanded; first issue not decided due to determinative second issue.
Compliance with findings of fact under § 211.181.1	Lindsay asserts insufficient factual findings to support jurisdiction.	State maintains findings were adequate or could be supplied on remand.	Remanded to enter proper findings of fact; additional evidence may be received on remand.

In re J.M., 328 S.W.3d 466 (Mo.App. E.D.2010) (clear and convincing evidence required; support for jurisdiction must be explicit)
In re E.K., 154 S.W.3d 453 (Mo.App. S.D.2005) (remand for proper § 211.181.3 findings when initial judgment lacking facts)
Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976) (sufficiency standard: substantial evidence, weight of evidence, and correct law)