Dept. of Human Services v. J. R. L

A juvenile court cannot rely on facts extrinsic to the jurisdictional judgment in determining the basis for continuing jurisdiction.

In this case, mother appealed a permanency judgment and a change in the permanency plan regarding A, her daughter. Jurisdiction over A originated from mother's admissions relating to A's exposure to risks of sexual abuse, a lack of suitable housing, and a failure to meet A's educational needs. A’s mother argued that the court erred when they denied the mother’s motion to dismiss jurisdiction and wardship over her daughter. In addition, she argued that the court erred in changing the permanency plan from reunification to adoption. The Court of Appeals agreed. In holding that the juvenile court erred, the Court of Appeals explained that the juvenile court's decision to continue jurisdiction was primarily based on the mother’s health. The mother's mental health was extrinsic to the jurisdictional judgment, and mother was not on notice regarding this issue. The Court held that because there is no way of knowing whether the juvenile court would have made the same ruling if they had only considered the original jurisdictional bases the case should be reversed and remanded. Reversed and remanded.