Adult Guardianship of Begay v. Etsitty

8 Navajo Rptr. 896
CourtNavajo Nation Family Court
DecidedJuly 11, 2006
DocketNo. WR-FC-1072-05
StatusPublished

This text of 8 Navajo Rptr. 896 (Adult Guardianship of Begay v. Etsitty) is published on Counsel Stack Legal Research, covering Navajo Nation Family Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adult Guardianship of Begay v. Etsitty, 8 Navajo Rptr. 896 (navajofamct 2006).

Opinion

[897]*897ORDER

This Order arises on Eleanor Begay’s Motion to Dismiss Petition for Guardianship. Having considered the motion, responsive pleadings and the record, and being otherwise fully informed, the court grants the motion for the following reasons:

PROCEDURAL HISTORY

The Petition for an Adult Guardianship was filed in August 2005 and the relevant procedural history is recited here to provide the backdrop for this order of dismissal. The individual who is the subject of this action is Eleanor Begay, an 89-year old woman. On September 2r, 2005 the then-presiding judge granted ex parte temporary guardianship to the petitioner, Rosalind Zah. Ms. Zah is Eleanor’s daughter. A final hearing was set for December 19, 2005. In October 2005 Ms. Shirley Etsitty, another of Eleanor’s daughters, was allowed to intervene as an interested party.

Before the final hearing the presiding judge entered an order of recusal, as did the other regularly-presiding judges in Window Rock. See Orders of Recusal, 12/9/05 and r2/T5/o5- The undersigned judge was assigned to preside over this matter on December 16, 2005. The final hearing was continued and this docket number was set for a pretrial conference on March 23, 2006. In addition, a guardian ad litem was appointed for Ms. Eleanor Begay, as was separate legal counsel. See Appointment of Guardian ad Litem for Ward and Appointment of Legal Counsel forward, r/23/06.

On March 17, 2006 Ms. Begay (through counsel) filed the pending Motion to Dismiss Petition for Guardianship. The pretrial conference was continued to allow for responsive pleadings to the request for dismissal. Order, 3/20/06.

Before the responsive pleadings were filed and the motion became ripe for review, an intervening event occurred: Petitioner filed a Motion for Emergency Teleconference because Ms. Eleanor Begay had been removed from the Payson Care Center without Ms. Zah’s knowledge or consent. The person who had removed Ms. Begay from the care center was Shirley Etsitty. A telephone conference was held on March 23rd, and resulted in the vacation of Ms. Zah’s temporary guardianship. Instead, “the Petitioner will retain legal custody of Ms. Begay and physical custody will be with the Intervenor until further order [898]*898of this court.” Minute Entry & Order, 3/23/06, p.2, fA. Ms. Zah’s request for reconsideration of that decision was denied. Order, 4/17/06.

Briefing resumed on the motion to dismiss, with a response filed by Ms. Etsitty on April 26th and a response by Ms. Zah filed on April 27th. Ms. Begay filed a reply to the motion on April 27, 2006. Petitioner filed a reply to Ms. Etsitty’s response on May 1,2006. All pleadings in response to the initial motion to dismiss were considered in the following analysis.

MOTION TO DISMISS: SUBSTANTIVE ANALYSIS

Ms. Begay argues that the petition for guardianship should be dismissed for a variety of reasons, each having to do with service of process and/or notice to Ms. Begay and how lack of proper notice violates her rights to due process. The Court agrees.

Service of Process was not accomplished pursuant to Nav. R. Civ. P. 4

The Navajo Nation Code requires that “[n]o judgment shall be given on any suit unless the defendant has been served notice in accordance with the applicable Court rules of such suit and given ample opportunity to appear in Court in his/ her defense.... “ 7 N.N.C. §604. As there are no specific rules for guardianship actions, the “applicable Court rules” in this suit are the Navajo Rules of Civil Procedure. Rule 4 details the requirement for service of process, emphasizing that personal service is a priority before other means of service will suffice.

In this case, everyone agrees that Ms. Eleanor Begay was not served in accordance with Rule 4.

Insufficient service of process has not been “cured” in this case

Our Supreme Court has considered whether insufficient service of process may be cured when a party, despite lack of service of process, nevertheless appears with counsel at a scheduled hearing. Yazzie v. Yazzie, 7 Nav. R. 203 (Nav. Sup. Ct. 1990). In Yazzie, the court held that although the party had not been served pursuant to the rules, he nevertheless was present and prepared to argue his case. “Any violation of the service rules was cured by the father’s appearance.” Id. at 204. The Court added that “[a]t no time did the father argue that he was prejudiced by the lack of proper service.” Id. This court understands that in some situations, procedurally deficient service may still protect a party’s due process if that party has actual notice and opportunity to be heard. However, in this case it cannot be so.

Ms. Eleanor Begay argues, and the court agrees, that she was prejudiced by the lack of service of process. The ex parte temporary guardianship was not granted until almost one month after the underlying petition was filed. Although this court is statutorily authorized to enter ex parte temporary or preliminary relief (7 N.N.C. §256) in some circumstances, the temporary guardianship need not have been ex parte had Ms. Eleanor Begay been served with the petition. It comports with both bilagaana legal principles as well as [899]*899Dine hi beenahaz’áanii that decisions made with the input from as many parties as possible are better than those made with input from only one.

Ms. Begay was removed from her home in September 2005, with all of the included deprivations of property and liberty, without notice of the underlying cause for the removal. At the time, she was not afforded the opportunity to present her Response to the Petitioner’s Petition. Ms. Begay may know of the petition for guardianship at this point, but it would be an inappropriate precedent to allow remedial actions to so easily cure a due process violation. Dinébi beenahaz’áanii principles of hazhó’ógo have been violated

In proceeding throughout this case, we seem to have forgotten that the people involved here are Nohookáá’ Dine’é dealing with other Nohookáá Dine’é. "When faced with important matters, it is inappropriate to rush to conclusion or to push a decision without explanation and consideration to those involved. Áádóó t’áána’nile’dii éidooda.” Navajo Nation v. Rodriquez, 8 Nav. R. 604, 615 (Nav. Sup. Ct. 2004).

Unfortunately, the provisions in our Navajo Nation Code for guardianship have not been updated since 1945.9 N.N.C. §§801-805. No procedural guidelines for guardianship actions have ever been created. For more than fifty years, whenever petitions for guardians are filed with the court (especially when the subject is an adult) procedures are inconsistent and often fail to protect the subject’s due process.

It is not permissible for this case to continue. To go along in the manner that the case has proceeded so far would be condoning the continued violation of Diñé bi beenahaz’áanii and Ms. Begay’s rights. The court acknowledges the difficulties caused by dismissing this action after so much time has passed, but it cannot be otherwise. The dismissal shall be without prejudice.

This court understands that as a lower tribunal its orders affect only this action and these parties. Nevertheless, it takes this opportunity to reflect on notice provisions that might be adopted and followed in all newly-filed guardianship actions. See Bizardi v.

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8 Navajo Rptr. 896, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adult-guardianship-of-begay-v-etsitty-navajofamct-2006.