Vonrio Hawkins v. In the Youth Court of DeSoto County, Mississippi, 223 So. 3d 187

Father Vonrio Hawkins was granted custody of his four children by DeSoto County Chancery Court in June 2012; the mother retained visitation.
In December 2015, the children reported abuse to their mother following visitation; youth-court proceedings followed.
At the youth-court hearing three children (ages 9, 11, 12, 14 at time of proceedings) testified describing repeated physical mistreatment (slapping, punching, choking, broom strikes, body slamming, kicking).
The youth court adjudicated the children abused and neglected and placed them in the custody of the Mississippi Department of Human Services.
Hawkins appealed, arguing (1) the chancery court’s prior custody order left the chancery court with exclusive, continuing jurisdiction over custody and thus the youth court’s order was void; and (2) the youth court’s abuse finding was not supported by substantial evidence and merely reflected corporal punishment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Youth court jurisdiction over abuse adjudication	Hawkins: chancery court’s prior custody order gave it exclusive continuing jurisdiction over custody, so youth court lacked subject-matter jurisdiction	Youth court/State: statutory scheme grants youth court exclusive original jurisdiction over abused-child proceedings unless chancery court elects to assume jurisdiction; chancery did not do so	Court: Youth court had jurisdiction; chancery’s continuing-jurisdiction doctrine does not divest youth court when chancery declines to assume abuse claims
Sufficiency of evidence that children were abused vs. disciplined	Hawkins: testimony unreliable, uncorroborated, constituted corporal punishment not abuse	State: children’s consistent testimony described unreasonable, repeated maltreatment beyond lawful corporal punishment; youth court as factfinder credited witnesses	Court: Evidence was sufficient; youth court reasonably found discipline unreasonable and therefore abusive/neglectful

Ladner v. Ladner, 206 So. 2d 620 (Miss. 1968) (principle that chancery court has continuing jurisdiction over custody decrees)
Wade v. Lee, 471 So. 2d 1213 (Miss. 1985) (county courts may enter temporary habeas corpus orders despite chancery custody decrees)
In re D.L.D., 606 So. 2d 1125 (Miss. 1992) (youth court jurisdiction over custody based on abuse despite chancery temporary order)
McDonald v. McDonald, 39 So. 3d 868 (Miss. 2010) (both chancery and youth courts can have jurisdiction over post-custody abuse allegations; chancery may elect to assume jurisdiction)
In re D.O., 798 So. 2d 417 (Miss. 2001) (standard of review in youth-court appeals; judge as factfinder)
In re A.R., 579 So. 2d 1269 (Miss. 1991) (discussion of corporal punishment and limits where punishment becomes abusive)
Tucker v. Tucker, 453 So. 2d 1294 (Miss. 1984) (custody-modification material-change discussion referenced by appellant)