Cocaine, due process, public policy.

Jessie Odom appeals a lower court's ruling that terminates her parental rights. State officials removed Odom's newborn child from her when they learned from hospital personnel that Odom had delivered the child at home and that both mother and child had tested positive for cocaine. The state outlined provisions that Odom would need to meet before regaining custody of her child. Odom failed to comply with those provisions and spent time in a corrections facility. The state initiated proceedings to terminate her parental rights.

The Superior Court of Allen County ordered the termination of Odom's parental rights. The court noted Odom had made little progress in improving her life and that the child was thriving in the care of foster parents. Odom now appeals.

Odom loses. The Indiana Court of Appeals affirmed the ruling of the lower jurisdiction. The court ruled there was no evidence to indicate the mother was capable of changing her lifestyle or improving the child's home life.