Section 12.18 Specificity of Allegations

• Library: Family Law Deskbook and 2014 Supp

2. (§12.18) Specificity of Allegations

The allegations of abuse and neglect triggering the mandatory appointment of the GAL must be stated with specificity. Walters v. Walters, 113 S.W.3d 214 (Mo. App. S.D. 2003); Castaneda v. Castaneda, 121 S.W.3d 324 (Mo. App. W.D. 2003). In Renfro v. Fehrmann, 817 S.W.2d 592, 593 (Mo. App. W.D. 1991), the court concluded that the mother’s modification allegation stating that “[t]he [Respondent] has permitted the minor children . . . to be exposed to conditions which could or would possibly endanger said minor childrens’ [sic] physical health” was not sufficient to require the appointment of a GAL because of vagueness and ambiguity.

In Renfro, the parties’ son had received successful chemotherapy treatments after being diagnosed with a malignant brain tumor although the father and mother had disagreed over the treatment that...