Parker v. Arkansas Department of Human Services, 2011 Ark. App. 18

Appellant Kristen Parker challenges the circuit court’s finding that MP, born November 26, 2008, was dependent-neglected.
MP was admitted to Arkansas Children’s Hospital on November 11, 2009 for fever, vomiting, and reduced oral intake; DHS alleged maternal tampering with MP’s IV and unnecessary requests for procedures.
DHS filed a petition for emergency custody on November 19, 2009 based on an affidavit detailing observed IV tampering, inconsistent histories, and other concerning behaviors by Parker.
The circuit court issued an emergency custody order and, after a probable-cause hearing, authorized supervised visitation.
At adjudication (February 11, 2009), witnesses including Parker, ACH staff, and others testified; the court found Parker’s explanations unsatisfactory and MP’s condition was attributed to Pediatric Condition Falsification/Munchausen by Proxy.
The court declared MP dependent-neglected, set reunification as the goal, and continued supervised visitation; Parker appealed contending insufficient evidence and lack of a formal MBP diagnosis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supports MP’s dependent-neglected finding	Parker argues no MBP diagnosis and no harm or unnecessary procedures were shown.	The DHS evidence showed parental unfitness and MBP as reported by medical staff; credibility favors the court.	Yes; evidence supports dependent-neglected finding.

In re Hope L., 278 Neb. 869 (Neb. 2009) (recognizes MBP concept and factual patterns)
Seago v. Arkansas Dep't of Human Servs., 360 S.W.3d 733 (Ark. 2009) (deference to trial court on credibility findings)