Glennon Bobo v. Anne-Marie Burkhammer and Taylor Burkhammer

── Glennon Bobo v. Anne-Marie Burkhammer and Taylor Burkhammer ── Court: Court of Appeals of Arkansas Date: May 13, 2026 Category: General Cite as 2026 Ark. App. 300 ARKANSAS COURT OF APPEALS DIVISIONS II & III No. CV-25-240 Opinion Delivered May 13, 2026 GLENNON BOBO APPEAL FROM THE LITTLE RIVER APPELLANT COUNTY CIRCUIT COURT [NO. 41PR-23-77] V. HONORABLE BRYAN CHESSHIR, ANNE-MARIE BURKHAMMER AND JUDGE TAYLOR BURKHAMMER APPELLEES AFFIRMED BRANDON J. HARRISON, Judge Glennon Bobo appeals the circuit court’s determination that his consent was not required for his two children (MC1 and MC2) to be adopted by Taylor Burkhammer, the children’s stepfather. He argues that the circuit court erred in entering the adoption order without the written, executed consent of the mother, Anne-Marie Burkhammer, appearing in the record and that the absence of that consent deprived the circuit court of subject- matter jurisdiction and rendered the adoption order invalid. We affirm. On 4 December 2023, Taylor and Anne-Marie filed a petition for adoption requesting that Taylor be allowed to adopt MC1 and MC2. They asserted that Glennon’s consent was not required because he had failed significantly without justifiable cause to communicate or to provide care and support for the children for a period of more than one year. Glennon moved to dismiss the petition for failure to state a claim on which relief may be granted; he argued that because child support had never been required by law or judicial 1 decree, he had not failed to provide support as required by law or judicial decree. Glennon also filed a separate proceeding to establish joint custody and child support. The court ordered that the two cases be consolidated and convened a hearing on 17 December 2024. At the hearing, Anne-Marie testified that she consented to Taylor adopting the children. In its written order, the circuit court found that Glennon’s consent to the adoption of the children was not required because for a period of at least one year, he had failed significantly without justifiable cause to communicate with the children or provide for their care and support. The court also found that Anne-Marie had consented to the adoption. Glennon timely appealed. Specific facts related to the points on appeal will be discussed below. We review adoption proceedings de novo, and a circuit court’s decision will not be set aside unless clearly erroneous. In re Adoption of A.M.P., 2021 Ark. 125, 623 S.W.3d 571. A finding is clearly erroneous when, despite evidence to support it, we are left with the firm conviction that a mistake has been made. Id. We defer to the circuit court’s superior vantage point on matters of witness credibility, and personal observations of the court are given great weight in cases involving the welfare of young children. Id. Glennon does not challenge the circuit court’s finding that he failed significantly without justifiable cause to communicate with the children or provide for their care and support for a period of at least one year. Instead, Glennon argues that Anne-Marie failed to file a written, executed consent to the adoption, and therefore the circuit court lacked subject-matter jurisdiction, the adoption is not valid, and the adoption petition should be dismissed. 2  I. Jurisdiction Arkansas Code Annotated section 9-9-206(a)(1) and (2) (Supp. 2025) provides that unless consent is not required under section 9-9-207, a petition to adopt a minor may be granted only if written consent to a particular adoption has been executed by bo