Jacob Earls, Appellant v. Arkansas Department of Human Services and Minor Children, S.m. and D.m., Appellees

Summary

The court reversed the termination of Jacob Earls's parental rights because the record did not establish his legal status as a biological parent before applying the statutory twelve-month grounds for termination. Although DNA testing showed a high probability that Earls was the children's father, the circuit court never made a clear legal finding establishing that status, so his parental rights had not attached for purposes of termination. Justice Wood, dissenting, would have affirmed because the circuit court sufficiently found Earls to be the biological and legal father and the statutory grounds were otherwise proven.