Angela Davidson v. Marlon Haynes

── Angela Davidson v. Marlon Haynes ── Court: Court of Appeals of Arkansas Date: May 20, 2026 Category: General Cite as 2026 Ark. App. 330 ARKANSAS COURT OF APPEALS DIVISION II No. CV-25-441 ANGELA DAVIDSON Opinion Delivered May 20, 2026 APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, V. THIRTEENTH DIVISION [NO. 60PR-24-1827] MARLON HAYNES APPELLEE HONORABLE MICHAEL REIF, JUDGE AFFIRMED STEPHANIE POTTER BARRETT, Judge Appellant, Angela Davidson (“Angela”), appeals the Pulaski County Circuit Court’s order denying her petition for single parent adoption. Angela argues on appeal that the circuit court erred in (1) finding the consent of appellee Marlon Haynes (“Marlon”) was required under Arkansas Code Annotated section 9-9-207(a)(2) (Repl. 2020); (2) finding that adoption was not in the best interest of the child; and (3) sustaining a hearsay objection at trial regarding whether the child knew Marlon is his father.1 We affirm. On August 13, 2024, Angela filed a petition to adopt her child, MC (DOB 10/21/17), as a single parent pursuant to Arkansas Code Annotated section 9-9-207(a)(2), 1 Arkansas Code Annotated section 9-9-207 was amended effective August 5, 2025. The events at issue occurred before the amendment; therefore, the opinion analyzes the statute as it existed before that date. alleging Marlon is the biological father of MC but had not been involved in MC’s life for over two years, he had not seen or communicated with MC since May 2022, and adoption was in the best interest of MC. On September 18, 2024, Marlon filed a response and a countermotion for visitation and custodial rights asserting that he is MC’s biological father, he had paid child support throughout MC’s life, and Angela had refused to allow visitation. Angela moved to dismiss the countermotion for lack of subject-matter jurisdiction, and the circuit court granted the motion and dismissed Marlon’s countermotion. A hearing on Angela’s adoption petition was held on April 14, 2025. Angela testified that MC was seven years old at the time of the hearing and that Marlon had never established parental rights. She further testified that Marlon had never called MC or asked MC to call him and had seen MC twenty-two times in seven years. Angela testified that the parties entered into an extrajudicial agreement in 2018, effective for two years, under which Marlon could have visitation with MC any day reasonable for her. She also testified that from 2018 to May 2022, she placed no restrictions on visitation, Marlon had her contact information and knew where she lived, and Marlon went more than one year without seeing MC during that period. When asked whether MC knows Marlon is his father, Marlon objected on hearsay grounds, and the circuit court sustained the objection. Angela testified that beginning in December 2022, she imposed the requirement that Marlon had to participate in counseling with MC before visitation would occur. She 2 explained that this requirement was her own decision. She stated that Marlon had not seen MC since May 2022, and they did not have a father-son relationship. She also stated that Marlon requested to see MC only four times in the last three years. She acknowledged that Marlon paid her $750 a month in child support beginning in 2018 and missed only one payment in seven years. Angela testified that the parties became involved in a business dispute in 2022 regarding a travel trailer, which led to litigation in the Pulaski County Circuit Cour