IN RE JUANITA M. - Articles

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Posted by: Julia Wilburn on Jan 16, 2026

Head Comment: BENNETT dissenting

Court: TN Court of Appeals

Attorneys 1: Angela W. Mueller, Trenton, Tennessee, for the appellant, Angela M.C.

Attorneys 2: Mark D. Johnston, Dyersburg, Tennessee, for the appellant, Hector M.C.

Attorneys 3: Jonathan Skrmetti, Attorney General and Reporter, and Jason R. Trautwein, Assistant Attorney General, for the appellee, Tennessee Department of Children’s Services.

Judge(s): FRIERSON

In this action to terminate parental rights, the mother, father, and child all tested positive for methamphetamine. Accordingly, the Tennessee Department of Children’s Services (“DCS”) took the child into protective custody, and the child was adjudicated dependent and neglected. Despite completing many of DCS’s requirements, the mother and father continued to fail drug tests. DCS filed a petition for termination of parental rights, and the trial court determined that three grounds supported termination as to both parents: (1) persistence of the conditions that led to the child’s removal, (2) severe child abuse, and (3) failure to manifest an ability and willingness to assume physical custody of or financial responsibility for the child. The trial court also concluded that termination of both parents’ rights was in the child’s best interest. Both parents have appealed. Discerning no reversible error, we affirm.