The Wyoming Supreme Court affirmed a juvenile court's decision to change a child's permanency plan from family reunification to adoption, rejecting the father's appeal in a case that highlights the complex legal standards governing child welfare proceedings.
In *In the Interest of DC*, decided January 7, 2026, the state's high court upheld the District Court of Platte County's ruling regarding the minor child DC, who was born in May 2023. The case involved father AC challenging the juvenile court's order that changed the permanency plan from reunification to adoption after DC had been in state custody for over 18 months.
The legal proceedings began approximately two months after DC's birth when the State of Wyoming filed a petition alleging both biological parents neglected the child by failing to provide adequate care. The Department of Family Services took custody of DC, initially establishing a permanency plan focused on family reunification.
Father AC argued before the Wyoming Supreme Court that the juvenile court abused its discretion when it changed the permanency plan to adoption. His primary contention was that the only barrier preventing reunification was his incarceration, and he claimed the Department of Family Services failed to make reasonable efforts to reunify him with his child.
The Wyoming Supreme Court, in an opinion authored by Justice Hill, rejected these arguments and affirmed the lower court's decision. The court examined whether the juvenile court properly exercised its discretion in modifying the permanency plan from reunification to adoption.
The case demonstrates the legal framework Wyoming courts apply when determining child welfare and permanency in contested custody matters. Under Wyoming law, juvenile courts must regularly review permanency plans and can modify them based on changing circumstances and the best interests of the child.
When a child has been in state custody for an extended period, courts must balance several competing interests: the fundamental right of parents to raise their children, the child's need for stability and permanency, and the state's obligation to protect children from neglect or abuse. The 18-month timeframe mentioned in the case is significant because federal and state laws generally require courts to make permanency decisions within specific timeframes to avoid prolonged uncertainty for children in care.
The father's incarceration presented a particular challenge for reunification efforts. While incarceration alone does not automatically terminate parental rights, courts must consider whether a parent can resume custody within a reasonable timeframe and whether continued delays serve the child's best interests.
The Department of Family Services' role in making "reasonable efforts" toward reunification is a critical legal standard in child welfare cases. Parents often argue that agencies failed to provide adequate services or support to help them address the issues that led to removal. However, courts also recognize that reasonable efforts have limits, particularly when children have been in care for extended periods.
The case was argued before the full Wyoming Supreme Court panel, including Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and Hill. Father AC was represented by Brittany Nicole Thorpe of Thorpe Law Office in Cheyenne. The state was represented by a team from the Attorney General's office, including Attorney General Keith G. Kautz, Deputy Attorney General Christina Faith McCabe, Senior Assistant Attorney General Wendy Susan Ross, and Assistant Attorney General Margaret Faye Laing.
Notably, the case also involved representation from the Wyoming Office of Guardian ad Litem, with Director Joseph R. Belcher and attorney Kimberly Skoutary Johnson representing the child's interests. Guardian ad litem representation ensures that the child's welfare remains the primary focus during legal proceedings, independent of either parent's or the state's position.
The Wyoming Supreme Court's decision in this case reinforces established precedent regarding permanency planning in child welfare cases. The court's affirmation of the adoption plan suggests that the juvenile court properly weighed the relevant factors, including the length of time in care, the barriers to reunification, and the child's need for permanent placement.
This ruling has implications for other parents facing similar circumstances in Wyoming's child welfare system. The decision emphasizes that while parental rights are fundamental, they are not absolute when children's safety and welfare are at stake. The case also highlights the importance of parents actively addressing the conditions that led to removal and working within the timeframes established by law.
The opinion, designated as *2026 WY 3*, will be published in the Pacific Reporter Third series after final review. The court noted that the opinion remains subject to formal revision before final publication.
For families involved in the child welfare system, this case underscores the critical importance of early intervention and compliance with court-ordered services to maintain the possibility of reunification before permanency plans shift toward adoption.