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Jennifer Nicole Hughes and David Wayne Hughes v. Arkansas Department of Human Services and Minor Children

2026-08-26

Summary

Holding. The Arkansas Court of Appeals affirmed the circuit court's adjudication that the minor children were dependent-neglected based on sexual abuse, finding sufficient evidence of penetrating genital trauma without disclosure by the child or identification of a specific perpetrator.

Seven-year-old twin girls were placed into the custody of the Arkansas Department of Human Services after one child sustained a significant internal tear to her vaginal wall that required surgical repair. The parents could not provide a clear explanation for the injury, offering instead speculative possibilities including a medical condition, jumping on a trampoline, a kidney stone, or early menstruation. Medical experts testified that the injury was consistent with penetrating sexual trauma and was highly atypical for accidental causes like falls or straddle injuries, which typically leave external damage. The parents argued on appeal that absent a specific disclosure from the child or eyewitness evidence of the abuse, the Department failed to meet its burden of proof for a dependency-neglect finding.

The appellate court affirmed the trial court's finding that the children were dependent-neglected due to sexual abuse. The opinion emphasized that no legal requirement exists for a child victim to disclose the abuse or for a witness to identify the perpetrator. The medical evidence established that a penetrating injury to the child's genitals had occurred recently, that only household members had access to her during the relevant timeframe, and that legitimate medical or accidental explanations were not supported by the evidence. The court also clarified that a dependency-neglect adjudication focuses on protecting the child from substantial risk of harm rather than establishing which parent or person caused the injury.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether medical evidence of unexplained penetrating genital injury in a child constitutes sufficient proof of sexual abuse for dependency-neglect without a child's disclosure or witness identification
  • Whether parental inability to explain a child's significant genital injury supports a dependency-neglect finding when the injury is consistent with sexual trauma
  • Whether identifying the specific perpetrator is necessary for a sexual abuse-based dependency-neglect adjudication

Procedural posture

Parents appealed the circuit court's adjudication of dependency-neglect entered after a hearing in which medical experts testified that their seven-year-old child sustained a penetrating vaginal injury requiring surgical repair, with no clear explanation provided by the parents or the child.

Authorities cited

Opinion

majority opinion

Cite as 2026 Ark. App. 372

ARKANSAS COURT OF APPEALS

II DIVISION

No. CV-26-107

JENNIFER NICOLE HUGHES AND Opinion Delivered: August 26, 2026

DAVID WAYNE HUGHES

APPELLANTS APPEAL FROM THE SEBASTIAN

COUNTY CIRCUIT COURT, FORT

V. SMITH DISTRICT

[NO. 66FJV-25-308]

ARKANSAS DEPARTMENT OF

HUMAN SERVICES AND MINOR HONORABLE SHANNON L. BLATT,

CHILDREN CIRCUIT JUDGE

APPELLEES

AFFIRMED

CASEY R. TUCKER, Judge

Jennifer Nicole Hughes (“Jennifer”) and David Wayne Hughes (“David”) appeal the

order of the Sebastian County Circuit Court adjudicating their twin seven-year-old

daughters, MC1 and MC2, dependent-neglected. Both Jennifer and David argue that the

Arkansas Department of Human Services (“the Department”) failed to sufficiently prove that

the children were dependent-neglected. We affirm.

I. Factual and Procedural Background

On September 8, 2025, the Department placed a hold on MC1 and MC2 because of

suspected sexual abuse of MC1 after receiving a report from the Arkansas State Police. Upon

questioning Jennifer and David, the Department learned that although Jennifer and David

were married, they slept in different rooms; MC1 and MC2 had slept in David’s bed, and

he had changed MC1’s pull-up diaper during the night; Jennifer discovered MC1’s pull-up contained bloody urine the next morning; MC1 continued to have blood in her pull-up,

which led Jennifer and David to take her to Arkansas Children’s Hospital (“ACH”); MC1

required four sutures to repair a tear in her vaginal wall; and MC1 had been with her parents

and three siblings exclusively during the forty-eight hours leading up to their arrival at ACH.

On September 10, the Department filed a petition for dependency-neglect and emergency

custody. The court entered an order granting the request for emergency custody of the

children the following day.

On September 15, the court held a probable-cause hearing and found an emergency

existed warranting the Department’s continued custody of MC1 and MC2. The adjudication

hearing was then set.

The adjudication hearing took place on October 27 and November 3 and 4.1 At this

hearing, the Department first presented the testimony of Dr. Todd Maxson, the pediatric

surgeon who repaired MC1’s vaginal tear. Dr. Maxson stated that MC1 required anesthesia

for examination. He found that MC1 had suffered a one-and-a-half- to two-centimeter

internal mucosal tear of her vagina, and she had developed blood clots within her vagina,

indicating it had bled before she was taken into the operating room. He did not find any

external injury to her vagina. Dr. Maxson placed four sutures in the mucosa to stop the

bleeding. He testified as follows regarding MC1’s type of injury:

Q. . . . Is this type of injury consistent with penetration trauma?

1

After adjudicating the minor children dependent-neglected, the court held a hearing on the disposition. Appellees’ brief discussed the testimony and evidence presented during the disposition; however, we did not consider this portion of the hearing.

2

A. It is.

Q. And is it your experience that an accidental fall could cause a posterior vaginal

injury -- tear?

A. I don’t see that. What we -- what I typically see where there’s a fall or a straddle

injury, probably is the most common, is I see some injury externally on the

vagina. I typically see some injury at the introitus to the vagina. I don’t believe

I’ve ever seen an isolated internal vaginal injury without injury to the -- to those

other parts of the genitalia from a fall.

Q. Would you expect fresh bleeding shortly after a traumatic event?

A. I would.

Q. In pediatric medicine, is an internal vaginal tearing considered a red flag for

sexual trauma?

A. It is considered a red flag, yes.

Dr. Maxson further testified that MC1 had no prior medical condition that would

cause this type of tear. He opined that an injury significant enough to go to the operating

room for bleeding with no explanation of how it occurred would lead him to consult the

TCAR team2 and a social worker.

Dr. Maxson conceded on cross-examination by David’s counsel that he did not know

what caused MC1’s vaginal tear. He was not asked to perform a rape-test kit, and thus, one

was not done.

2

TCAR stands for ACH’s Team for Children at Risk for sexual abuse and neglect.

3

On cross-examination by Jennifer’s counsel, Dr. Maxson testified that MC1’s hymen

was still intact. On redirect examination, Dr. Maxson explained that MC1’s hymen could

remain intact after sexual penetration had occurred.

The next witness to testify was Dr. Sara Golden, who was designated as an expert

witness without objection. Dr. Golden is an ACH child-abuse pediatrician who reviewed

MC1’s medical records. Dr. Golden testified that vaginal bleeding in a seven-year-old is

abnormal and that MC1’s laceration indicated that trauma occurred. Dr. Golden was

questioned about the severity of MC1’s type of injury and what that meant:

Q. . . . The need for sutures, I’m sorry, does it indicate a more minor

or more severe type injury?

A. I would say that the need for sutures indicates that this is a

significant injury.

Q. In your opinion, is a posterior vaginal tear in a seven-year-old

warrant concern for sexual abuse and why?

A. Yes, it does.

A. . . . The reason being is that seven-year-old children ideally would

not have any vaginal bleeding at all. In the event that they have

lacerations, like I mentioned previously, it’s the result of trauma.

When speaking to the child directly, she denied self-insertion of

any objects or falling onto objects, and so penetrating vaginal

trauma from sexual abuse is very high on the differential diagnosis.

Given that David and Jennifer noticed fresh blood in three pull-ups on the morning

of the surgery, Dr. Golden believed that MC1’s injury had occurred recently. When asked

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about the causes of MC1’s injury, Dr. Golden stated that this injury could not be caused

during the normal care of a seven-year-old. While she acknowledged that an injury like

MC1’s could be accidental, in MC1’s particular case, the family did not provide a history of

accidental trauma.

Dr. Golden testified that from a child-maltreatment medical perspective, MC1’s type

of injury justified continued protective custody by the Department until the safety of the

minor children could be ensured since there was a high concern for sexual abuse. Dr. Golden

acknowledged that MC1 denied being a victim of sexual abuse and that MC1 had

developmental delays; however, Dr. Golden stated that, in her experience, denial is common

in victims of sexual abuse and that children with developmental delays are at a higher risk

for sexual abuse.

When asked about the mechanism for the potential sexual abuse, Dr. Golden stated

that it was unknown but that it could have been caused by way of a penis, a finger, or an

object. She stated her belief that the caregivers should have had an explanation for MC1’s

injury given the fact that she was only seven years old at the time.

When asked whether MC1 could have caused this injury to herself by way of

masturbation, Dr. Golden explained that it is uncommon to see actual penetrative actions

with child masturbation; however, in the rare instance that it does occur, it is typically seen

in young adults. Further, she stated that she had never personally seen penetrative

stimulation in a child MC1’s age.

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Shelby Bouren (“Shelby”), the ACH clinical social worker, testified next. Shelby stated

that she was assigned to MC1’s case and that she interviewed the parents about MC1’s injury.

Shelby stated that they denied having any precise knowledge about the cause of MC1’s injury.

Shelby stated that she also interviewed MC1. MC1 denied any knowledge of how her

injury occurred, and she acted out how David assisted her with changing her pull-up through

the night. Shelby noted that when she asked MC1 about the cause of her injury, MC1

became tearful and began to cry. Shelby testified that when she attempted to provide support

to MC1 during this time, MC1 denied that she was crying.

The next witness to testify was the investigator assigned to the case, Bobby Woodrome

(“Bobby”), who was employed by the Sebastian County Sheriff’s Office. Bobby stated that he

had intended to do a rape test in the case; however, he stated that he was unable to do so

because ACH had failed to properly preserve the evidence. Bobby testified that he

interviewed David and Jennifer separately.

When Bobby asked Jennifer and David about what they thought had caused MC1’s

injury, they could not give Bobby a clear answer; instead, they offered the following as

possible causes: MC1’s medical issues, jumping on the trampoline, a kidney stone, or that

she could have started her period early. No criminal charges were filed against Jennifer or

David.

The next witness was an investigator with the Arkansas State Police Crimes Against

Children Division (“CACD”), Carley Zirbel (“Carley”). Carley asked Jennifer and David

what occurred the day before they took MC1 to ACH. Jennifer and David also gave Carley

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the same possible explanations for how MC1’s injury could have occurred. Jennifer and

David told Carley that only they and MC1’s siblings had access to MC1 in the preceding

forty-eight hours. Additionally, Carley stated that she expected the parents to provide her

with an accurate explanation of the injury, and because they could not, she was concerned

for both MC1’s and MC2’s safety.

Mary Duenas (“Mary”), a social service specialist with the Department, testified that

after MC1 and MC2 were removed, she spoke with Jennifer, who was unable to provide her

with an explanation for the injury. This concerned Mary because MC1 had a significant

injury without explanation that was caused by an unknown offender. She was also concerned

about the sleeping arrangements during the time frame of the injury.

Jennifer testified next. She stated that on the night of September 6, she and their

oldest daughter went to a banquet while David watched the other three children. When they

returned home, MC1 and MC2 were just getting out of the bathtub, and her son was asleep

in his room. She said that the girls put on their pull-ups, she told them goodnight, and then

they went into David’s room to watch TV. Jennifer said she did not know exactly when they

fell asleep in David’s bed. Jennifer stated that she slept in the office that night and likely

went to sleep around 2:00 or 3:00 a.m. When she woke up the next morning, she saw that

the pull-up MC1 had worn the previous night appeared to contain light pink urine. After

MC1 had two more bloody pull-ups, she and David took her to the hospital around 12:00

p.m.

7

At the conclusion of Jennifer’s testimony, the attorneys made their closing arguments,

and the circuit court issued an oral ruling on the adjudication portion of the hearing.

On November 20, the court found that Jennifer’s testimony was not convincing and

entered an adjudication order that MC1 and MC2 were dependent-neglected due to sexual

abuse with severe trauma by unknown offender and parental unfitness. The court found the

allegations in the petition were true, and the vaginal injury to MC1 was consistent with

penetration and bleeding. The court further found oversight was necessary to protect the

children from the risk of sexual abuse, and without a known offender, there was no viable

safety plan.

After receiving an Arkansas Rule of Civil Procedure 54(b) certification, Jennifer and

David appealed.

II. Legal Framework

The purpose of an adjudication hearing is to determine whether the allegations in

the petition are substantiated by the proof. Ark. Code Ann. § 9-35-316(a)(1)(A) (Supp. 2025);

see Araujo v. Ark. Dep’t of Hum. Servs., 2019 Ark. App. 181, at 4, 574 S.W.3d 683, 685. The

burden of proof at an adjudication hearing is a preponderance of the evidence. Id., 574

S.W.3d at 685.

On appeal, appellate courts use de novo review, will defer to the circuit court’s

credibility determinations, and will not reverse the circuit court’s order unless its findings

were clearly erroneous. Id; see also Samuels v. Ark. Dep’t of Hum. Servs., 2016 Ark. App. 2, 479

S.W.3d 596. “A finding is clearly erroneous when, although there is evidence to support it,

8

the reviewing court on the entire evidence is left with a definite and firm conviction that a

mistake has been made.” Id. at 6–7, 479 S.W.3d at 600.

Only one ground is necessary to support a dependency-neglect finding. Franklin v. Ark.

Dep’t of Hum. Servs., 2022 Ark. App. 390, 654 S.W.3d 76. The Juvenile Code defines a

dependent-neglected juvenile to include any juvenile who is at substantial risk of serious

harm as a result of, among other things, sexual abuse. Ark. Code Ann. § 9-35-102(17)(a)(iii)

(Supp. 2025). The definition of sexual abuse includes deviant sexual activity, by a caretaker,

to a person younger than eighteen years of age. Ark. Code Ann. § 9-35-102(54)(D). Deviant

sexual activity is defined as any act of sexual gratification involving penetration, however

slight, of the labia majora or anus by a body member or foreign instrument. Ark. Code Ann.§

9-35-102(20)(B).

III. Jennifer’s Appeal

Jennifer argues on appeal that the circuit court clearly erred in finding there was

sufficient evidence to support a finding of dependency-neglect. Because only one ground is

necessary to support a dependency-neglect finding, we focus on whether there was sufficient

evidence to support the circuit court’s finding of sexual abuse and need not determine

whether the evidence independently established other grounds for a finding of dependencyneglect. Franklin, supra.

Jennifer argues that “there is almost always a disclosure by the child or direct witness

evidence for this court to affirm a finding of sexual abuse.” She contends that because MC1

did not testify or tell any of the providers how the injury occurred, nor did any witness

9

disclose how MC1 was injured, the Department did not meet its burden of proof. There is

no requirement that a disclosure be made by a witness to sustain a finding of sexual abuse.

Jennifer cites no authority for this claim, and we do not consider arguments without

convincing argument or citation to authority. Ward v. Ark. Dep’t of Hum. Servs., 2014 Ark.

App. 491. On the contrary, Dr. Golden testified that denial is common in victims of sexual

abuse. The court also heard from the clinical social worker, Shelby, who testified that when

she asked MC1 about the cause of her injury, MC1 became tearful and began to cry.

Jennifer’s argument is not well taken.

Jennifer fails to acknowledge the numerous witnesses who testified on behalf of the

Department. The court weighed the evidence and testimony and found the Department met

its burden of proof by a preponderance of the evidence—it was more likely than not that the

children were dependent-neglected. See Turner v. State, 2017 Ark. App. 682, 537 S.W.3d 299.

Jennifer argues there is no indication that the injury to MC1 was for the purpose of

sexual gratification as required by Arkansas Code Annotated section 9-35-102(20)(B). This

argument is without merit.

We have held it is not necessary for the state to provide direct proof

that an act is done for sexual gratification if it can be assumed that the desire

for sexual gratification is a plausible reason for the act. McGalliard v. State, 306

Ark. 181, 813 S.W.2d 768 (1991). We have previously stated that “when

persons, other than physicians or other persons for legitimate medical reasons,

insert something in another person’s vagina or anus, it is not necessary that

the state provide direct proof that the act was done for sexual gratification.”

Id. [at 183, 813 S.W.2d at 769].

10

Warren v. State, 314 Ark. 192, 196–97, 862 S.W.2d 222, 225 (1993). The testimony of the

witnesses supported the determination that MC1 suffered a penetrating injury to her vagina

without further damage to the external tissues. Clearly, something had been inserted into

her vagina. Dr. Golden testified that without a legitimate medical basis or accidental injury,

some type of sexual trauma—whether from a penis, a finger, or an object—caused MC1’s

injury. In light of Warren, the court could infer the act was done for sexual gratification. The

court did not clearly err in finding there was sufficient evidence to meet the element of sexual

gratification given the location of MC1’s injury and that there was no legitimate medical

reason or accidental basis for the injury.

Jennifer’s argument that the expert witness testimony did not chin the necessary bar

of substantial evidence of sexual abuse falls short. Dr. Golden testified that “[w]hen speaking

to the child directly, she denied self-insertion of any objects or falling onto objects, and so

penetrating vaginal trauma from sexual abuse is very high on the differential diagnosis.”

Similarly, Dr. Maxson ruled out a fall or straddle injury because there was no external vaginal

trauma and only internal trauma. Dr. Maxson stated that in pediatric medicine, vaginal

tearing is “considered a red flag” that warrants bringing in the TCAR team for evaluation.

Both Dr. Maxson and Dr. Golden testified that an injury to a child’s genitals—especially one

significant enough to require surgical repair to stop the bleeding and having no known

explanation—presents an ongoing medical risk to the child.

To the extent Jennifer argues that a particular cause must be identified, we find

Franklin, supra, persuasive. In Franklin, the parents of a seven-week-old denied knowing how

11

the child obtained multiple skeletal fractures; instead, they speculated that the injuries were

caused by the older sister jumping and falling on the child. Id. at 1–2, 654 S.W.3d at 77–78.

The court heard testimony from three physicians as to the nature and extent of the child’s

injuries and how they could have occurred. The court found the child dependent-neglected

on the grounds of abuse. The father appealed, arguing that there was no identified act or

omission or evidence the injuries were not accidental. Id. at 2–4, 654 S.W.3d at 77–79. We

affirmed the finding of dependency-neglect in the absence of any potential medical cause or

plausible accidental injury. Though there was conflicting testimony about the potential

causes of the injury, the court was free to believe the testimony that supported the finding

of abuse. Id.

Over the course of three days, the court heard witness testimony that MC1 suffered

an acute injury that had occurred within forty-eight hours of arriving at the hospital, and

only the people in the home had access to her. The testimony of the expert and treating

physician detailed how this seven-year-old child suffered a penetrating mucosal tear to her

vagina that was significant enough to warrant four sutures to stop the bleeding. This is

abnormal by all accounts. The court weighed the testimony and considered the possible

explanations offered by Jennifer and David—her underlying medical condition,3 starting her

menstruation cycle, accidental fall, or kidney stone—and instead chose to believe that MC1

suffered a penetrating injury without further external trauma, which could be caused by a

3

The only testimony presented was that MC1 was developmentally delayed, and she has polymastia. Neither of these would explain an internal posterior vaginal tear.

12

penis, a finger, or an object, as testified to by the medical experts. The court found Jennifer’s

testimony unconvincing and instead found the testimony of the expert, treating physician,

social worker, and CACD investigator more persuasive. The circuit court was in the best

position to evaluate the testimony of the witnesses and determine the weight to be given to

their testimony. See Araujo, supra. “[T]his court will not substitute its own judgment or

second-guess the credibility determinations of the trial court.” Hambrick v. Ark. Dep’t of Hum.

Servs., 2016 Ark. App. 458, at 12, 503 S.W.3d 134, 140.

Jennifer argues that because the investigator with the sheriff’s office, Bobby, “said it

could not be and was not Jennifer,” the adjudication order as to her should be reversed. She

argues that Bobby’s testimony supports her argument that she did not cause MC1’s injury.

The court did not have to give weight to Bobby’s testimony. Regardless of what weight the

court gave Bobby’s testimony, an adjudication of dependency-neglect occurs without

reference to which parent committed the acts or omissions leading to the adjudication; the

juvenile is simply dependent-neglected. Eason v. Ark. Dep’t of Hum. Servs., 2012 Ark. App.

507, 423 S.W.3d 138. Because of this, “[t]he focus of an adjudication hearing is on the child;

not the parent[.]” Young v. Ark. Dep’t of Hum. Servs., 2018 Ark. App. 270, at 6, 549 S.W.3d

383, 386–87. The child must be protected regardless of precisely who or what placed him or

her at substantial risk of serious harm. Franklin, supra.

We cannot say that the circuit court clearly erred in finding that the children were

dependent-neglected based on sexual abuse and affirm.

IV. David’s Appeal

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David argues on appeal that the evidence does not support the circuit court’s finding

that the children were dependent-neglected due to sexual abuse and parental unfitness. Only

one ground is necessary to support a dependency-neglect finding; therefore, we do not

address David’s argument regarding parental fitness. Franklin, supra. David makes many of

the same arguments as Jennifer’s—no disclosures, unknown offender, and Bobby’s testimony

do not support a finding of dependency-neglect.

To the extent David argues that the Department failed to prove he was the perpetrator

of any alleged sexual abuse, we have frequently held that a parent cannot avoid the legal

consequence of a dependency-neglect finding at the adjudication stage just because the

alleged sexual abuse might have been caused by someone else. Eason, supra. “It is not

uncommon for trial courts at the adjudication stage to find abuse or neglect but also find that

the offender is unknown.” Parnell v. Ark. Dep’t of Hum. Servs., 2018 Ark. App. 108, at 23, 538

S.W.3d 264, 278.

For the reasons discussed in our consideration of Jennifer’s appeal, we also reject

David’s arguments and hold that the circuit court did not clearly err in finding the children

dependent-neglected.

Affirmed.

GLADWIN and BARRETT, JJ., agree.

Leah Lanford, Arkansas Commission for Parent Counsel, for separate appellant David

Wayne Hughes.

Dusti Standridge and Tara Crippen, for separate appellant Jennifer Hughes.

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Ellen K. Howard, Ark. Dep’t of Human Services Office of Chief Counsel, for appellee.

Linda J. Hamilton, attorney ad litem for minor children.

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