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In the Interest of L. A.

The juvenile court failed to make specific factual findings to support its ruling that a 1-year-old child was deprived as to the father.

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The father of now one-year-old L. A. appeals from a dispositional order of the Juvenile Court of Walton County in which the court ruled that the child was deprived as to him. The father contends that the court based its ruling on facts that were not in evidence, improperly shifted the burden of proof, applied the wrong legal standard, and supplanted Georgia law with its own judgment. For the following reasons, we vacate the finding of deprivation as to the father and remand with direction.

As a threshold matter, we note that the appellee’s brief indicates that, subsequent to the docketing of this appeal, the juvenile court issued another disposition order finding that L. A. is no longer deprived as to the father and transferring custody of L. A. to him for a period of two years. However, such order is not in the record on appeal. And as the earlier finding of deprivation may have future collateral consequences against the father—i.e., in petitioning another court for permanent custody—we decline to dismiss the appeal as moot. See generally In the Interest of T. H., 319 Ga. App. 216, 218-220 735 SE2d 287 2012.

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