When a parent is detained, the children are hours away from an emergency shelter placement. Capture the kinship caregiver on the record and hand the court a placement declaration before the child-welfare agency files.
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Placement keeps the children in the same school
Caregiver has cared for the children before
Child protective agency already contacted / shelter petition threatened
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Orange County, Florida · Circuit Court · Speedy trial: Fla. R. Crim. P. 3.191 · Release: Fla. R. Crim. P. 3.131; Fla. Stat. § 903.046
[Florida — Inability-to-pay / Bearden ROR proffer] Your Honor, R.M. on case 2026-CF-004182. Before we go further: my client has [N] minor child(ren) — [CHILDREN] — who were in my client's care at the time of the arrest. [CAREGIVER], the children's [RELATIONSHIP], is present and willing to take immediate placement at [ADDRESS], reachable at [PHONE]. I'm filing a kinship placement declaration and asking the Court to direct that the children be released to that relative rather than to emergency shelter care, and to stay any shelter proceeding long enough for the relative to be screened. Your Honor, my client is indigent. Under Bearden v. Georgia, 461 U.S. 660 (1983), and Fla. R. Crim. P. 3.131; Fla. Stat. § 903.046, the Court may not detain by setting a bond my client has no ability to post without first inquiring into that ability and considering alternatives. We ask the Court to make that inquiry on the record and grant release on personal recognizance, or on conditions no more restrictive than necessary to secure appearance and community safety, as required by Fla. R. Crim. P. 3.131; Fla. Stat. § 903.046.