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Domestic Relations-Protective Custody-Cessation of Reunification Efforts

Staff Report//April 22, 2026//

Domestic Relations-Protective Custody-Cessation of Reunification Efforts

Staff Report//April 22, 2026//

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Mother appealed the trial court’s order relieving the children’s division from making further efforts to reunify mother with her children. The division’s petition followed the placement of the children into protective custody after mother allegedly attempted to strangle one child and smother another with a pillow. On appeal, mother argued that the trial court erred in making its decision without evidence.  

Where the division failed to present any evidence to substantiate the allegations of mother’s violence towards the children, the trial court erred in relieving the division from further reunification efforts.   

Judgment is reversed and vacated.  

In the Interest of: I.J.L. (MLW No. 84643/Case No. WD88220 & WD88221 – 13 pages) (Missouri Court of Appeals, Western District, Pfeiffer, J.) Appealed from circuit court, Cole County, Fretwell, J. (David J. Moen, Jefferson City for appellant) (Joseph M. Page, Jefferson City for respondent) 

 


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