In re Interest of Jeremy U.
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The Supreme Court reversed the decision of the juvenile court declining to adjudicate a newborn that reportedly tested positive for methamphetamine on the grounds that the State failed to prove that he was at risk of harm, holding that the evidence demonstrated that the newborn lacked proper parental care due to his mother's fault or habits.
The State sought to adjudicate the newborn, who had been in a hospital with Mother, and his two siblings, who lived with and received appropriate care from their grandmother, solely on the basis that the children lacked proper parental care. The juvenile court declined to adjudicate the children. The Supreme Court affirmed the juvenile court's decision as to the older siblings because they did not lack proper parental care but reversed as to the newborn, holding that the newborn lacked proper parental care, as demonstrated by Mother's drug use during pregnancy until the time of his birth.
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