Dcpp v. D.C.A. and J.J.C.B.

CourtSupreme Court of New Jersey
DecidedNovember 16, 2023
DocketA-44-22
StatusPublished

This text of Dcpp v. D.C.A. and J.J.C.B. (Dcpp v. D.C.A. and J.J.C.B.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dcpp v. D.C.A. and J.J.C.B., (N.J. 2023).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Division of Child Protection and Permanency v. D.C.A. (A-44-22) (087604)

Argued September 12, 2023 -- Decided November 16, 2023

PATTERSON, J., writing for a unanimous Court.

In this appeal, the Court determines whether trial courts may still consider the relationships between children and resource families under the fourth prong of the best interests of the child test, N.J.S.A. 30:4C-15.1(a)(4), despite a 2021 Amendment that precluded consideration of those relationships under the test’s second prong, N.J.S.A. 30:4C-15.1(a)(2).

Defendants “Divina” and “Javier” are the parents of “Ignacio,” born in 2015; “Josefina,” born in 2016; “Antonia,” born in 2019; and “Ian,” born in 2020. The record reflects extensive evidence of domestic violence involving Divina and Javier. In July 2018, the trial court granted the Division of Child Protection and Permanency care, custody, and supervision of Ignacio and Josefina, citing concerns about continuing domestic violence, Divina’s inability to provide a safe environment for the children, and Divina’s mental health. Antonia and Ian were each removed from the home shortly after birth. Ignacio and Josefina were placed together in a resource home; Antonia and Ian were each placed in different resource homes.

The Division presented the testimony of its expert psychologist about the mental health of the parents and his bonding evaluations of the four children with Divina. In the case of each child, he found that the child had an “ambivalent and insecure” attachment to Divina and that the child did not have a “significant and positive bond” with her. The psychologist opined as to each child that there was a low risk that the child would suffer severe and enduring harm if the child’s relationship with Divina were terminated. He also testified about the bonding evaluations that he conducted to assess the relationships between Antonia and Ian and their respective resource families, which had expressed the intent to adopt.

The Division next presented caseworker testimony. During cross- examination, the Law Guardian inquired how the children were doing in their current placements. Divina’s counsel objected, arguing that in the wake of the 2021 Amendment to N.J.S.A. 30:4C-15.1(a), such evidence was no longer relevant.

1 The trial court overruled that objection, noting that the Legislature prohibited consideration of such evidence in the court’s inquiry under the second prong of the best interests test, but not in the court’s determination of the other prongs of the test. Ultimately, the trial court found that the Division had proven by clear and convincing evidence all four prongs of N.J.S.A. 30:4C-15.1(a) and terminated the parental rights of Divina and Javier to Ignacio, Josefina, Antonia, and Ian.

The Appellate Division affirmed, rejecting Divina’s argument that the Legislature’s amendment of N.J.S.A. 30:4C-15.1(a)(2) barred trial courts from considering evidence of the child’s relationship with resource parents in any aspect of the termination of parental rights determination. 474 N.J. Super. 11, 24-30 (App. Div. 2022). The Court granted certification. 253 N.J. 599 (2023).

HELD: Based on the plain language of the 2021 Amendment, the Court concurs with the trial court and Appellate Division that the Legislature did not intend to bar trial courts from considering evidence of the child’s relationship with the resource family when they address the fourth prong of N.J.S.A. 30:4C-15.1(a). The trial court properly considered the relationships between the children and their resource families when it considered the fourth prong of the best interests test, N.J.S.A. 30:4C-15.1(a)(4), and its determination as to all four prongs of that test was grounded in substantial and credible evidence in the record.

1. In New Jersey, the balance between parental rights and the State’s interest in the welfare of children is achieved through the best interests of the child standard . The Court reviews the history of the standard, which began as a generally phrased statute in 1951. The Court set forth a four-factor test to apply that statute in DYFS v. A.W., 103 N.J. 591, 604-11 (1986). In 1991, the Legislature enacted the original version of N.J.S.A. 30:4C-15.1(a), codifying in subsections (a)(1) through (a)(4) the four- prong test defined in A.W. The 1991 iteration of the termination of parental rights statute did not expressly direct courts to evaluate the child’s relationship with the resource family as part of the best interests analysis. That specific direction was explicitly added to the second prong of the test -- N.J.S.A. 30:4C-15.1(a)(2) -- via legislative amendment in 1995 following the Court’s recognition of the importance of that evaluation in In re Guardianship of J.C., 129 N.J. 1, 19 (1992). (pp. 20-24)

2. Although the relationship with the resource family was only explicitly added to the second prong of the best interests test as codified in statute, the Court explained that it was also relevant under the fourth prong -- N.J.S.A. 30:4C-15.1(a)(4) -- in In re Guardianship of K.H.O., 161 N.J. 337, 353-55 (1999), and subsequent case law. In short, by the time the Legislature amended N.J.S.A. 30:4C-15.1(a) in 2021, New Jersey courts had long considered a child’s relationship with a resource family to be relevant not only when they assessed the evidence under the second prong of the best interests test, but also when they applied the fourth prong. (pp. 24-26) 2 3. In July 2021, the Legislature removed the instruction to consider the relationship with the resource family that had been added to N.J.S.A. 30:4C-15.1(a)(2) in 1995. A statement to the bill that proposed the amendment explained the legislation’s intent to require the Division “to consider placement of children with relatives or kinship guardians” when determining the placement of children, and to change “certain standards for initiating petitions to terminate parental rights.” The rest of N.J.S.A. 30:4C-15.1(a) was left unchanged. The fourth prong of the best interests test continues to require that a court determine whether “[t]ermination of parental rights will not do more harm than good.” N.J.S.A. 30:4C-15.1(a)(4). (pp. 26-29)

4. The Legislature made a single change to N.J.S.A. 30:4C-15.1(a) in 2021: the deletion of the sentence, “[s]uch harm may include evidence that separating the child from his resource family parents would cause serious and enduring emotional or psychological harm to the child,” from N.J.S.A. 30:4C-15.1(a)(2). It amended N.J.S.A. 30:4C-15.1(a)(2) to ensure that parental fitness -- not the child’s bond with resource parents -- is the core inquiry when a judge considers the best interests standard’s second prong in a termination of parental rights case. It did not identify as a legislative goal the elimination of that bond as a factor in any component of the best interests analysis. Indeed, as the Appellate Division noted, precluding the admission of all evidence concerning resource family placements could in some settings undermine the Legislature’s objective to promote kinship caregivers and preserve family bonds. See 474 N.J. Super. at 25-26. In L. 2021, c. 154, which amended no fewer than eight statutes, the Legislature could easily have barred evidence of a child’s relationship with resource parents in a court’s inquiry under the fourth prong of the statutory standard, or entirely precluded consideration of such evidence in any aspect of a court’s inquiry.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

New Jersey Division of Youth & Family Services v. E.P.
952 A.2d 436 (Supreme Court of New Jersey, 2008)
In Re the Guardianship of J.C.
608 A.2d 1312 (Supreme Court of New Jersey, 1992)
New Jersey Division of Youth & Family Services v. G.L.
926 A.2d 320 (Supreme Court of New Jersey, 2007)
New Jersey Division of Youth & Family Services v. A.W.
512 A.2d 438 (Supreme Court of New Jersey, 1986)
DiProspero v. Penn
874 A.2d 1039 (Supreme Court of New Jersey, 2005)
In Re the Guardianship of K.H.O.
736 A.2d 1246 (Supreme Court of New Jersey, 1999)
Johnson v. Scaccetti
927 A.2d 1269 (Supreme Court of New Jersey, 2007)
New Jersey Division of Youth & Family Services v. M.M.
914 A.2d 1265 (Supreme Court of New Jersey, 2007)
New Jersey Div. of Youth and Family Services v. Ar
965 A.2d 174 (New Jersey Superior Court App Division, 2009)
Cherry Hill Manor Associates v. Faugno
861 A.2d 123 (Supreme Court of New Jersey, 2004)
In the Int of: D.C.D./ Appeal of: Clinton Co C&YS
105 A.3d 662 (Supreme Court of Pennsylvania, 2014)
New Jersey Division of Child Protection and Permanency v. Y.N. (072804)
104 A.3d 244 (Supreme Court of New Jersey, 2014)
In re H.J.
200 A.3d 891 (Supreme Court of New Hampshire, 2018)
Bennett v. Jeffreys
356 N.E.2d 277 (New York Court of Appeals, 1976)
Ryan v. Renny
999 A.2d 427 (Supreme Court of New Jersey, 2010)
New Jersey Division of Youth & Family Services v. F.M.
48 A.3d 1075 (Supreme Court of New Jersey, 2012)
New Jersey Department of Children & Families v. A.L.
59 A.3d 576 (Supreme Court of New Jersey, 2013)
State v. Rangel
64 A.3d 558 (Supreme Court of New Jersey, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Dcpp v. D.C.A. and J.J.C.B., Counsel Stack Legal Research, https://law.counselstack.com/opinion/dcpp-v-dca-and-jjcb-nj-2023.