Full Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO. 2025-SA-00342-COA IN THE INTEREST OF M.T., A MINOR: M.B APPELLANT v. WARREN COUNTY DEPARTMENT OF THE APPELLEES MISSISSIPPI DEPARTMENT OF CHILD PROTECTION SERVICES, AND MISSISSIPPI DEPARTMENT OF CHILD PROTECTION SERVICES DATE OF JUDGMENT: 03/13/2025 TRIAL JUDGE: HON. MARCIE TANNER SOUTHERLAND COURT FROM WHICH APPEALED: WARREN COUNTY YOUTH COURT ATTORNEY FOR APPELLANT: J. ALLEN DERIVAUX JR. ATTORNEYS FOR APPELLEES: KRISTI DUNCAN KENNEDY BRYAN C. WARDLAW NATURE OF THE CASE: CIVIL - DOMESTIC RELATIONS DISPOSITION: AFFIRMED - 11/10/2026 MOTION FOR REHEARING FILED: BEFORE BARNES, C.J., McCARTY AND LASSITTER ST. PÉ, JJ. McCARTY, J., FOR THE COURT: ¶1. A child was removed from his mother’s care and placed with a foster parent. The child’s biological father was incarcerated at that time. Several years later, the father was released on parole and sought custody of his son. ¶2. The father entered into an agreement with Child Protection Services for the purposes of seeking reunification with his son. But the father failed to complete the terms of the agreement. ¶3. CPS petitioned to terminate the father’s parental rights on several grounds. These grounds included abandonment, being unfit to parent, an unwillingness to provide basic needs, failing to visit or communicate, and neglectful conduct that was causing a substantial erosion of the relationship. ¶4. After a hearing, the county court found it was in the child’s best interest to terminate the father’s parental rights. The father appeals. Finding no error, we affirm. FACTS AND PROCEDURAL HISTORY ¶5. The subject of this appeal is the termination of parental rights. More specifically, a father’s rights regarding his 10-year-old son, M.T. ¶6. M.T. is the biological son of Mark and Candace.1 Mark was incarcerated out-of-state when M.T. was born and for the first 9 years of his life. M.T. lived with Candace from his birth through February 2020. ¶7. In 2020, CPS intervened due to allegations of abuse by Candace and her boyfriend. CPS removed M.T. from Candace’s care and placed him in the custody of a foster family. ¶8. Three years later, Mark was let out on parole. Sometime after his release in 2023, he contacted CPS asking to see M.T. and seeking custody. He was granted supervised visitation, though the details of when or how are not established in the record before this Court.2 The 1 We refer to the child and the family members by use of initials and pseudonyms to protect the child’s privacy and anonymity. 2 The youth court conducted the proceedings on the abuse allegations, while the county court conducted the subsequent TPR proceedings. The youth court records from the underlying abuse case were not provided to the county court as part of the TPR case or made a part of this record on appeal, except for one adjudication order, one disposition order and one permanency order. It also appears that almost none of the records from CPS’s case file were provided either, other than the family service plan document. 2 first supervised visit for Mark occurred in November 2023. ¶9. Six months later, Mark entered into a Family Service Plan with CPS to pursue reunification with M.T. The service plan required Mark to secure stable housing, obtain and provide proof of stable employment, participate in supervised visits, attend parenting classes, and provide a hair follicle sample for testing. ¶10. That June, the CPS social worker assigned to M.T.’s case, Ms. Hill, conducted a walk- through of Mark’s house and confirmed he had stable housing. Hill later testified that Mark attended most of his scheduled supervised visits with M.T. But CPS was not able to confirm that he completed the other 3 requirements. She explained Mark failed to provide pay stubs as proof of employment, attend the parenting classes, or report to the lab for his hair follicle test. ¶11. About three and a half months later, CPS took action seeking to terminate Mark’s parental rights to M.T.3 CPS filed its TPR petition with the County Court of Warren County and served Mark via publication. CPS then filed a motion requesting the appointment of a Guardian Ad Litem, which the county court granted. ¶12. A hearing on the TPR petition was set for December 4, 2024. But Mark was a no-show in court that day, so the county court continued the case against Mark to March 2025. ¶13. In late December, CPS conducted a supervised visit with Mark and M.T. at a 3 Prior to CPS filing its TPR petition, Candace signed a form voluntarily surrendering her parental rights to M.T. CPS’s petition also sought to formally terminate the parental rights of Candace, M.T.’s mother. 3 Christmas party for foster families. This would turn out to be Mark’s last visit with M.T. ¶14. Ten days later, Mark was arrested and incarcerated out-of-state again. ¶15. The hearing on CPS’s TPR petition against Mark occurred over the course of 2 days, March 3 and March 7, 2025.4 Notably, Mark was incarcerated in Louisiana under federal custody. Efforts to have him transported to the Warren County courthouse were unsuccessful, so Mark attended the hearing remotely via video-teleconference on the platform Zoom. While Mark was not able to be there in person, he was represented by counsel who was physically present at the hearing. Measures were also taken for Mark’s attorney to be able to confer with him via video conference. ¶16. CPS presented evidence in the form of testimony from CPS social worker, Ms. Hill, and the GAL, Ms. Cade, as well as the GAL’s written report and recommendation. ¶17. At the hearing, Hill testified that during several supervised visits, Mark became aggressive with M.T., snatching a toy [] out of M.T.’s hands and making him cry. She also relayed that Mark gave M.T. ultimatums, threatening to abandon M.T. if he did not choose Mark over his foster family. Hill’s testimony also explained that M.T. had “stated that his father was trying to bribe him,” and “uses money and things to try and get him to come with [Mark].” ¶18. In turn, Mark took the witness stand via Zoom and testified on his own behalf. He did not present any other evidence. 4 In the course of the hearing on the first day, concerns arose as to whether Mark had been properly notified of the case. As a result, the county court recessed and continued the proceedings to allow counsel to investigate. Four days later, the TPR proceedings resumed. 4 ¶19. Thereafter, the county court entered its judgment terminating Mark’s parental rights of M.T. on March 13, 2025. ¶20. In its judgment, the county court determined that M.T. “was placed in the full physical and legal custody of Warren County Department of MDCPS on February 14, 2020, by Order of the Warren County Youth Court[;]” and “was placed in an approved foster home where he has remained under the continuous supervision and control of said [CPS].” ¶21. Mark subsequently filed motions for a judgment notwithstanding the verdict and for a new trial, but both were denied. Aggrieved, Mark appeals. STANDARD OF REVIEW ¶22. “The standard of review and statutory basis for termination of parental rights is quite limited.” X.G.C. v. Jackson Cnty. Dep’t of Child Prot. Servs., 400 So. 3d 451, 457 (¶22) (Miss. 2025) (quoting A.H. v. K.M., 323 So. 3d 509, 513 (¶22) (Miss. 2021)). ¶23. On appeal, the “judge’s findings of fact are viewed under the manifest error/substantial credible evidence test.” S.F. v. Lamar Cnty. Dep’t of Child Prot. Servs., 373 So. 3d 985, 987 (¶8) (Miss. 2023) (quoting Vance v. Lincoln Cnty. Dep’t of Pub. Welfare, 582 So. 2d 414, 417 (Miss. 1991)). “[W]e will not reverse when ‘credible proof exists to support the [judge’s] findings of fact by clear and convincing evidence.’” R.B. v. Winston Cnty. Dep’t of Child Prot. Servs., 291 So. 3d 1116, 1120 (¶9) (Miss. Ct. App. 2019) (quoting W.A.S. v. A.L.G., 949 So. 2d 31, 34 (¶7) (Miss. 2007)). ¶24. “In complying with this standard, ‘this Court asks not how it would have decided the case ab initio but whether credible proof exists to support the judge’s findings of fact by clear 5 and convincing evidence.’” S.Z.O. v. Harrison Cnty. Dep’t of Child Prot. Servs., 396 So. 3d 1225, 1235-36 (¶45) (Miss. Ct. App. 2024) (quoting S.F., 373 So. 3d at 987 (¶8)). “[W]e will affirm the [county] court’s judgment if substantial evidence supports at least one ground found by the [county] court.” C.D.M. v. Lee Cnty. Dep’t of Child Prot. Servs., No. 2024-CP-01427-COA, 2026 WL 2167289, at *7 (¶26) (Miss. Ct. App. July 28, 2026). DISCUSSION ¶25. Mark raises four issues on appeal, specifically whether the county court erred by: (1) terminating his parental rights of M.T.; (2) conducting the TPR hearings with Mark appearing virtually; (3) carrying out the proceedings without having first advised Mark of his statutory rights; and (4) failing to respond to Mark’s request for a certain witness to be present at the TPR hearings. We address each issue in turn. I. The termination of Mark’s parental rights was supported by clear and convincing evidence. ¶26. The crux of Mark’s argument is “Whether or not the [county] [c]ourt erred in finding by clear and convincing evidence that the parental rights of [Mark] should be terminated.” ¶27. On appeal, Mark contends that the county court order “lists, among other grounds, that [Mark] has engaged in conduct constituting abandonment or desertion, that [Mark] is mentally, morally or otherwise unfit to raise [M.T.]; that [Mark] is unwilling to provide food, clothing or shelter and that [Mark] has failed to exercise reasonable visitation or communication.” But he alleges “[t]he evidence in this case against [him] does not rise to the level of clear and convincing.” 6 ¶28. According to Mark, “his testimony that he desires a relationship demonstrates a lack of abandonment regarding his child[.]” He further argues “CPS caseworker [Ms.] Hill testified that [M.T.] knows who his father is” and she “admitted that [M.T.] has a working relationship with his father.” He emphasized that “he sent cash-app payment of hundreds of dollars to his former CPS worker for his son while he was in custody,” and “that he spoke to his son every day until he was incarcerated.” ¶29. Mississippi Code Annotated “[s]ection 93-15-115 applies to any involuntary termination of parental rights where, as here, reasonable efforts are required for reunification of a child in CPS custody.” S.Z.O., 396 So. 3d at 1236 (¶49). ¶30. “The [county] court was authorized to terminate [Mark’s] parental rights ‘if, after conducting an evidentiary hearing, the court finds by clear and convincing evidence that’” CPS has met the following four conditions: (a) The child has been adjudicated abused or neglected; (b) The child has been in the custody and care of, or under the supervision of, CPS for at least six (6) months, and, in that time period, CPS has developed a service plan for the reunification of the parent and the child; (c) A permanency hearing, or a permanency review hearing, has been conducted . . . and the court has found that CPS, or a licensed child caring agency under its supervision, has made reasonable efforts over a reasonable period to diligently assist the parent in complying with the service plan but the parent has failed to substantially comply with the terms and conditions of the plan and that reunification with the . . . parent is not in the best interests of the child; and (d) Termination of the parent’s parental rights is appropriate because reunification between the parent and child is not desirable toward obtaining a satisfactory permanency outcome based on one or more of the grounds set out in Section 93-15-119 or 93-15-121. Id. at 1236 (¶49) (quoting Miss. Code Ann. § 93-15-115). 7 The First Three Conditions for Termination of Mark’s Parental Rights ¶31. On appeal, Mark does not challenge the county court’s findings as to the first 3 statutory conditions so we only briefly discuss those findings. ¶32. First, it is uncontested that the youth court entered an order adjudicating M.T. an “abused child.” Second, it is further undisputed that M.T. had been in CPS’s custody for well over six months. M.T. entered CPS’s custody in February 2020, more than 5 years before Mark’s TPR hearing in 2025. ¶33. Third, evidence showed Mark entered into a Family Service Plan with CPS in May 2024. According to the GAL report, after Mark entered into this service plan, the youth court conducted several review hearings discussing his efforts toward reunification.5 ¶34. The GAL report submitted to the county court advised that “the last Permanency Review Hearing [was] held on August 15, 2024.” However, later testimony from CPS social worker Ms. Hill during the TPR hearing suggested that the actual date of the youth court’s last review hearing was December 10, 2024. Nevertheless, Hill’s testimony and the GAL’s testimonial presentation of her report were in agreement that during the preceding youth court case, the “court found CPS had made reasonable efforts.” ¶35. Based on the fact that Mark does not challenge the underlying findings of the youth court, we cannot say that the third condition listed in the statute, which requires permanency hearings, was not met. 5 The appellate record fails to include the contents of the youth court’s entire record from the underlying abuse case. The series of events that occurred in youth court giving rise to this termination action are not clear, because they were not provided to this Court to aid in our review. 8 The Fourth Condition for Termination of Parental Rights ¶36. “Section 93-15-115[(d)] allows termination of parental rights based on the grounds set out in either section 93-15-119 or section 93-15-121 if any of the reasons are established ‘by clear and convincing evidence’ and if the court finds that ‘reunification between the parent and child is not desirable toward obtaining a satisfactory permanency outcome.’” E.H. v. Lee Cnty. Dep’t of Child Prot. Servs., 420 So. 3d 341, 351 (¶42) (Miss. Ct. App. 2025) (citing Miss. Code Ann. §§ 93-15-119, 93-15-121). Crucially, “[t]his statutory provision plainly provides that only one statutory ground under either section . . . is necessary[.]” S.Z.O., 396 So. 3d at 1237-38 (¶54) (emphasis added). ¶37. Among other grounds, the county court in this case found that there was clear and convincing evidence to terminate Mark’s parental rights because it was “not desirable” for M.T. Specifically, the county court found Mark was “unfit” to raise M.T. ¶38. In relevant part, “section 93-15-119 authorizes a court to terminate the parental rights of a parent” when: the parent . . . is mentally, morally, or otherwise unfit to raise the child, which shall be established by showing past or present conduct of the parent that demonstrates a substantial risk of compromising or endangering the child’s safety and welfare . . . . S.Z.O., 396 So. 3d at 1237-38 (¶55) (quoting Miss. Code Ann. § 93-15-119(1)(a)). ¶39. The county court relied on the presented testimony, the GAL’s report and recommendation, and the documentation in evidence to support finding that the requirements of the statutory law were satisfied. ¶40. The record includes evidence of Mark’s unseemly behavior; his conduct towards M.T. 9 during supervised visitation that was aggressive, threatening, and included attempts to bribe the child; and his repeated failure to comply with the service plan. We find that evidence of Mark’s conduct is credible proof supporting the county court’s finding that clear and convincing evidence demonstrated that Mark posed a substantial risk of compromising M.T.’s welfare, and therefore, was “unfit” to raise M.T. 1. Criminal Behavior ¶41. The GAL’s report states, “The following grounds for TPR were alleged in the petition,” and recounted: Since [Mark’s] release, he has failed to comply with his service plan, continues to be investigated by law enforcement, is not consistent with his visitation, has failed to establish stable housing and employment, failed to submit to drug testing, and has failed to complete parenting classes. [Mark]’s past and on going legal troubles and his unwillingness to obtain and maintain stability, demonstrate that he is morally unfit to raise [M.T.] and [Mark] poses a substantial risk to [M.T.] [Mark] has not shown that he has stable employment or housing, he continues to have on going issue with law enforcement evident by his recent arrest, incarceration and indictment for several charges, including rape. ¶42. The transcripts from the county court’s two-day TPR hearing reflect that the GAL then provided the following testimony: [GAL]: The next ground that was alleged is that he is mentally, morally, or otherwise unfit. I would again state the incarcerations do show his moral unfitness to be involved with [M.T.]. .... [COURT]: [Mark] was incarcerated back in 2020 or thereabout when this child was placed in CPS custody. Is that correct? [GAL]: That is correct. [COURT]: What was - - why was he incarcerated at that time? [GAL]: He just testified that it was the distribution of a controlled 10 substance. [COURT]: Okay. And he received one hundred and . . . . twenty months, I believe, that was his testimony. . . . [GAL]: He is now incarcerated. There are three indictments out of . . . Louisiana.[6] ¶43. During this sequence of testimony, the county court specifically asked the GAL, “So it is your testimony as the Guardian Ad Litem that you have investigated [Mark’s] background or criminal background or at least the indictments that are pending right now[?]” The GAL responded affirmatively and advised the court that “based on the criminology of his behavior that he is mentally unfit.” ¶44. Consequently, we find the evidence reasonably supports that Mark’s conduct and actions toward M.T. justify the conclusion that Mark was unfit to raise M.T. See Int. of J.K., 304 So. 3d 184, 195 (¶36) (Miss. Ct. App. 2020) (“Kirkley’s illegal activities and continuous incarceration were of his own making; it was not the fault of the court or the DHS;” “we reiterate the CPS’s argument that Kirkley had an opportunity to demonstrate that he ‘could maintain a stable, drug free lifestyle,’ but he continued to use drugs and ‘engage in criminal behavior’”). 2. Aggressive, Threatening, and Bribery Acts/Conduct 6 The GAL then listed out, on the record, the charges in each indictment. The first contained 2 charges: “Video Voyeurism,” and “Second Degree Rape.” The second indictment included 5 charges: Count 1, Second Degree Rape. . . . Count 2, Video Voyeurism. . . . Count 3, Federal[] Carnal Knowledge of A Juvenile. . . . Count 4, Indecent Behavior With a Juvenile. . . . Count 5, Third Degree Rape. The third indictment asserted 1 charge for “Third Degree Rape.” 11 ¶45. The county court heard sworn testimony that Mark’s ongoing behavior made it impossible to place M.T. in his care and custody. At the hearing, CPS social worker Hill testified: I observed [Mark] being kind of more aggressive with [M.T.]. . . . He was informing [M.T.] that it is either him or the foster parent. It was like he gave him an ultimatum. [M.T.] had a player’s card within his grasp, in his hand. [Mark] snatched the card and told [M.T.] that if he don’t choose him that he would just leave. He won’t get anything any more and he will be gone. ¶46. CPS’s counsel specifically asked Hill, “Did you observe on the part of [M.T.], the child, any sort of anger at his father or fear of his father?” She responded, “The child did cry during that visit[.]” Hill then further testified that [Mark] stated to the child that the foster-parent was brain-washing him. .... [M.T] stated that his father was trying to bribe him. He stated that his father uses money and things to try to get him to come with him. The county court also heard testimony from the GAL that Mark’s supervised visits “started to be issues, as Ms. Hill has testified to, and ultimately [the youth court] suspended those visits due to the effect it was having on [M.T.].” ¶47. This sequence of testimonial evidence supports finding Mark unfit based on past conduct and ongoing behavior in his interactions with M.T. 3. Failure to Comply with the Service Plan ¶48. Our case law establishes that a parent’s failure to comply with the requirements of CPS’s service plan can support finding the parent “unfit” to raise the child. See S.Z.O., 396 So. 3d at 1239 (¶62) (“evidence that S.Z.O. was ‘unfit’ and that reunification would not lead to a satisfactory permanency outcome was S.Z.O.’s repeated failure to comply with the 12 reunification service plan and youth court orders”). ¶49. In this case, Mark’s repeated failure to comply with his service plan was evidence Mark was “unfit” to raise M.T. One of the terms of his service plan with CPS required him to attend a designated parenting class program. But Mark admitted repeatedly that he did not attend any of the required parenting classes. He conceded that he signed up to take the classes, but then gave excuses as to why he failed to complete them. This failure to attend parenting classes supports the county court’s finding that Mark was not fit to parent M.T. Because Mark had been incarcerated during M.T.’s whole life—10 years at that point, the parenting classes were critical to building his relationship with M.T. ¶50. Therefore, we conclude the county court did not err in finding, by clear and convincing evidence, that it was in M.T.’s best interest to terminate Mark’s parental rights. ¶51. Because we find no error in the county court’s finding that there was clear and convincing evidence to terminate Mark’s parental rights on the ground that he was an unfit parent, a further analysis of Mark’s other arguments regarding the grounds of abandonment or desertion, willingness to provide basic needs, and exercise of visitation or communication is not necessary. See M.A.S. v. Lamar Cnty. Dep’t of Child Prot. Servs., 353 So. 3d 460, 481 (¶64) (Miss. Ct. App. 2021). ¶52. The court then entered its judgment terminating Mark’s parental rights to M.T. But it is critical to point out that the court’s order consisted only of mere boilerplate findings—there was not a single detail relevant to Mark’s case. Rather, the county court entered a judgment that is akin to a mere form order when it rendered this decision on 13 whether to terminate a father’s rights, which is an issue of fundamental magnitude. ¶53. “We strive mightily to respect limitations upon our role where appeals are taken regarding issues of fact. The process breaks down, however, where the trial court sitting without a jury does not independently make findings of fact.” Rebuild Am. Inc. v. Colomb, 344 So. 3d 864, 871 (¶19) (Miss. Ct. App. 2022) (quoting Tricon Metals & Servs. v. Topp, 516 So. 2d 236, 239 (Miss. 1987)). This is critical because the “[f]ailure to provide this Court with findings of fact and conclusions of law precludes us from performing our appellate duties.” Id. (quoting Fulop v. Suta, 847 So. 2d 893, 895 (¶4) (Miss. Ct. App. 2002)). In short, for this Court to effectively “consider whether a trial court committed manifest error, it must tell us what it did.” Id. II. The county court did not commit any reversible procedural errors. ¶54. Mark also identifies multiple procedural errors by the county court. He argues the court erred by failing to provide him with the proper statutory notices at the beginning of the hearing, by conducting the hearing with his remote attendance, and by failing to grant his requested witness subpoena. A. The county court advised Mark of his rights. ¶55. Mark argues that “[a]t the TPR hearing in the opening procedures by the [c]ourt,” he “was not advised of the five statutory rights as required.” He contends, “[c]ertainly [Mark] was represented by Counsel at the TPR hearing but the presence of an attorney does not eliminate the required advisement of rights under the statute.” ¶56. Mississippi Code Annotated section 93-15-113 holds: 14 (2)(a) At the beginning of the involuntary termination of parental rights hearing, the court shall determine whether all necessary parties are present and identify all persons participating in the hearing; determine whether the notice requirements have been complied with and, if not, determine whether the affected parties intelligently waived compliance with the notice requirements; explain to the parent the purpose of the hearing, the standard of proof required for terminating parental rights, and the consequences if the parent’s parental rights are terminated. The court shall also explain to the parent: (i) The right to counsel; (ii) The right to remain silent; (iii) The right to subpoena witnesses; (iv) The right to confront and cross-examine witnesses; and (v) The right to appeal, including the right to a transcript of the proceedings. Miss. Code Ann. § 93-15-113 (Rev. 2021). ¶57. In In re K.B., 424 So. 3d 908, 911 (¶17) (Miss. Ct. App. 2025), this Court held that “[b]ecause [the mother] was represented by counsel, fully took part in the TPR hearing, and was ultimately advised of her right to appeal, [she] suffered no harm from the court failing to explicitly inform her of her rights at the beginning of the TPR hearing.” In short, “the mother exercised all the rights that she now complain[ed] the court failed to give her.” Id. ¶58. Similarly, in another case, “the judge confirmed at the outset of the hearing that both Ashley and Jeremy were represented by separate counsel.” Ashley R. v. Warren Cnty. Dep’t of Child Prot. Servs., 431 So. 3d 896, 902 (¶29) (Miss. Ct. App. 2026). But in the midst of the hearing, “the judge seemingly realized that she had not advised Ashley and Jeremy of their rights,” so the hearing was halted. Id. The judge then “advised [Jeremy] and Ashley of the purpose of the hearing, the burden of proof, their right to remain silent, and their right to appeal.” Id. Both parents then “affirmed that they understood the purpose of the hearing and 15 their rights and that they had been represented by counsel throughout the proceeding.” Id. ¶59. Ashley appealed “assert[ing] that the youth court erred by not advising her of her rights at the beginning of the hearing as required” by statute. Id. at (¶28). This Court found the mother “was represented by counsel at all times, she was advised of her rights prior to her testimony, and she exercised her rights, including her right to appeal.” Id. at 903 (¶31). Consequently, we “again remind[ed] our youth courts of the importance of advising parents of their rights at the beginning of the termination hearing,” but found “the deviation from the statute was harmless error on the facts of this case.” Id. ¶60. In this case, Mark was represented by a court-appointed attorney throughout both days of the TPR hearing. The county court advised Mark that “if at any point and time if you need to speak with your attorney just raise your hand and Mr. Bonner will see that and the [c]ourt will recess court . . . if you have any concerns or questions for him at this hearing.” ¶61. His counsel advised the county court at the beginning of the hearing: “I have informed him of his rights to his governmental constitution.” Mark’s counsel received and reviewed the proffered evidence, cross-examined CPS’s witnesses, and made several objections on Mark’s behalf. ¶62. The transcripts reflect that part way through the hearing, the following exchange occurred: [BONNER]: [Mark,] you have the right to testify if you want to, to the Bench. But if you do testify anything that you may say - - [COURT]: Let me inform him. .... [COURT]: [Mark] you have the constitutional right to remain silent. Anything that you say can be used against you. You are 16 represented by competent counsel. You’ve been represented by Mr. Bonner throughout this proceeding. In fact, the Court has stopped several times during this proceeding, and that not being a problem. But had to stop several times in order for you to meet with and speak with your attorney. So, what the Court is telling you now, is you have the right to testify. That is you’re absolute right. And you have the right not to testify which is also your absolute constitutional right not to testify because you will then be subject to cross examination and anything you say in this courtroom can be held against you. Do you understand your rights? [MARK]: Yes, ma’am, I do. ¶63. Then at the end of the hearing, the transcripts reveal: [COURT]: . . . This Court has stopped the proceedings, taken recesses at least four, and perhaps 5 or 6 times so that [Mark], his constitutional rights, rights of due process which are so important to not only him but to this Court and sure as to all the officers of the Court as well. But . . . for the record, these proceedings were stopped many times for [Mark] to speak with his attorney and address the Court as on the transcripts on several occasions. . . . this Court will . . . issue its opinion . . . as to whether or not the burden of proof of clear and convincing evidence should terminate the parental rights of . . . father, [Mark], should be terminated. The county court continued, “If the rights of [Mark] are terminated, [Mark] will have 30 days to appeal the [c]ourt’s decision to the Supreme Court.” In turn, both Mark and his counsel confirmed to the county court that they understood Mark’s right to appeal and the deadline. ¶64. The same reasoning as In re K.B. and Ashley R. applies to this case. Mark was represented by counsel, he participated in the 2-day TPR hearing, his counsel cross-examined CPS’s witnesses, and he was advised of his right to appeal. While Mark is correct that the county court failed to explicitly inform him at the beginning of the hearing of his statutory rights, he has not shown that he suffered any harm from this error. Therefore, any error was 17 harmless. B. The county court did not err by conducting the proceeding with Mark attending remotely. ¶65. Next, Mark argues his attorney “objected to [Mark] attending by [remote] means and asserted that this procedure deprived him of his right to consult with counsel.” He alleges that “[t]he problem with attendance by [Z]oom is twofold: First, the testimony by [Z]oom effectively limited and constricted his right to attend, defend and actively participate in the TPR hearing. Second, his right to adequate opportunity to consult with counsel was negatively impacted.” ¶66. On appeal, Mark recounts: “Counsel for the Warren County Department of Child Protection Services advised the [c]ourt that [Mark] was unavailable for personal appearance because he was in Federal Custody” at a correctional facility located in Louisiana. “In addition, [the] Warden” of the “Correctional Center, testified that to attend [Mark] would have to have a waiver of extradition.” ¶67. He argues that “[t]he representations of Counsel for CPS and the [prison] Warden in the instant case as to [Mark’s] unavailability, although understandable, are not sufficient to overcome the impact on his rights to counsel and his right to personally appear at his case.” According to Mark, he is housed in a “Correctional Facility [that] is 22 miles from Warren County Youth Court,” and “[t]his distance should certainly be no bar to his attending in person.” ¶68. This Court previously addressed video appearance at a court hearing and held “that such testimony may be allowed if the trial court makes the requisite finding of necessity as 18 well as reliability;” however, “we are not holding that remote testimony violates the Confrontation Clause per se.” Stevenson v. State, 357 So. 3d 1141, 1154 (¶43) (Miss. Ct. App. 2023). ¶69. Here, the hearing transcripts are replete with discussions between the county court, Mark’s counsel, and the warden at the prison where Mark is incarcerated. The statements from Mark’s counsel and the court make it clear that substantial efforts were taken by his counsel and CPS to have him transported for the hearing. However, the warden’s testimony was unequivocal that Mark “had a federal detainer” and “he has a federal hold” that did not allow simply driving him from the prison in Louisiana to the court in Warren County. ¶70. The county court inquired, “could he have been transferred to Warren County, Mississippi for this hearing this morning while in federal hold and while in custody at the jail?” The warden explained that there were several steps involved and that it would “require a waiver” of extradition “and we would have to release him to Mississippi. [] He would have to sign a waiver here and then Mississippi would have to pick him up and then to bring him back we would have to have a waiver signed by a judge to come back.” He further explained, “But due to the charges they are not going to release him to Mississippi until he is done in Louisiana.” ¶71. In turn, the county court found “[Mark’s] rights have not been nor will they be violated in this courtroom,” and proceeded with the hearing with Mark attending via remote video conference. In light of the county court’s extensive inquiry into Mark’s situation, we cannot find that the court erred in conducting the hearing via video-conference. 19 C. The county court was not responsible for subpoenaing Mark’s witnesses. ¶72. In his last issue, Mark alleges he “testified that he wanted a witness to testify on his behalf,” and “identified this witness as [Ms.] Moore, [a] CPS caseworker with whom he had worked with for four years.” But according to Mark, “the [c]ourt did not appear to address [Mark’s] request for her attendance.” He argues “[t]his was possibly detrimental to his case and he should have been afforded the opportunity to have the potential witness produced.” ¶73. “Rule 28(a)(7) of the Mississippi Rules of Appellate Procedure requires an appellant’s argument to ‘contain the contentions of appellant with respect to the issues presented, and the reasons for those contentions, with citations to the authorities, statutes, and parts of the record relied on.’” Mazie v. Boozier-Mazie, 400 So. 3d 503, 511 (¶21) (Miss. Ct. App. 2024). “In the absence of meaningful argument and citation of authority, appellate courts generally will not consider the assignment of error.” Id. (quoting Reading v. Reading, 350 So. 3d 1195, 1199 (¶19) (Miss. Ct. App. 2022)). ¶74. Mark fails to provide any legal authority in support of this argument. Therefore, we will not consider this assignment of error. CONCLUSION ¶75. We find no error in the county court’s decision to terminate Mark’s parental rights to M.T. Further, we find Mark’s arguments regarding the procedural aspects of the hearing do not constitute reversible error. Accordingly, the judgment of the County Court of Warren County, Youth Court Division, is affirmed. ¶76. AFFIRMED. 20 BARNES, C.J., CARLTON AND WILSON, P.JJ., LAWRENCE, EMFINGER, WEDDLE AND LASSITTER ST. PÉ, JJ., CONCUR. McDONALD, J., CONCURS IN PART AND IN THE RESULT WITHOUT SEPARATE WRITTEN OPINION. WESTBROOKS, J., CONCURS IN RESULT ONLY WITHOUT SEPARATE WRITTEN OPINION. 21