In re Certified Question from the Crownpoint Family Court

8 Am. Tribal Law 377
CourtNavajo Nation Supreme Court
DecidedMarch 2, 2010
DocketNo. SC-CV-50-07
StatusPublished

This text of 8 Am. Tribal Law 377 (In re Certified Question from the Crownpoint Family Court) is published on Counsel Stack Legal Research, covering Navajo Nation Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Certified Question from the Crownpoint Family Court, 8 Am. Tribal Law 377 (navajo 2010).

Opinion

OPINION

The Court answers a certified question from the Crownpoint Family Court concerning conflicting provisions of the Children’s Code. The presiding judge requested a ruling as to how the following provisions of Children’s Code should be interpreted: 9 N.N.C. § 1055(C)(1) which states that “[j]urisdietion obtained by a Family Court over a child is retained until terminated by ... [t]he child becoming] an adult, except where a child becomes an adult during the pendency of proceedings in the Family Court” and 9 N.N.C. § 1156(H) which states that “[wjhen a child reaches 18 years of age all judgments affecting the child then in force automatically terminate”. We hold that 9 N.N.C. § 1055(C)(1) is superseded by 9 N.N.C. § 1156(H).

I

A young member of the Navajo Nation under the age of 18 years is charged with two counts of battery and one count of criminal damage. There is an admission to all the charges. The young man is then held to be a delinquent under the law and the court places the individual on probation. The Prosecutor subsequently flies a petition for revocation of the probation because the young man is alleged to have committed another delinquent act contrary to the conditions of probation. A preliminary hearing is held on the revocation petition on November 20, 2007. The court rules that probable cause has been shown that a delinquent act did occur and the court orders that the young man be detained until an adjudication hearing is held on the revocation petition. The court schedules the hearing for December 5, 2007. On December 4, 2007 the young man turns 18 years old and, thus, is now an adult under the law.

In a similar case in the same court only three months before, the court determined that when 9 N.N.C. § 1055(C)(1) is read in conjunction with 9 N.N.C. § 1156, any possible interpretation of § 1055(C)(1) that the court’s jurisdiction over a minor who turns 18 prior to final judgment of the charges continues until the court’s final judgment is superseded by § 1156’s mandate that all judgments still in force affecting the young person “automatically terminate” when the person turns 18 years old. The court read the interaction between the two statutes from a very practicable perspective—it ruled that even if the court had continuing jurisdiction over the person who now is an adult, any judgment it made “would be null and void the instant it was signed” pursuant to § 1156(H), making any proceeding it conducts “legally irrelevant.” The court then ordered the release of the young man at 12:01 a.m. on the day he turned eighteen.

In the instant case the court filed a petition on November 21, 2007 seeking a [379]*379ruling from this Court as to how the two statutes should be interpreted. The court requested for a ruling prior to December 4, 2007 but it also informed the Court that it would release the young man upon his 18th birthday. The court thereon released the young man at 12:01 a.m. on December 4, 2007 and dismissed all the cases against the young man. The Court accepted the certified question for review on October 14, 2009. The Office of the Prosecutor submitted its position on October 29, 2009. This opinion follows.

II

The issues are (1) whether a court’s petition to have this Court answer a certified question is rendered moot by the same court’s dismissal of the underlying proceedings and (2) how should eourts of the Navajo Nation resolve the conflict between the two following provisions of the Children’s Code; 9 N.N.C. § 1055(C)(1) which states that “[¡Jurisdiction obtained by a Family Court over a child is retained until terminated by ... [t]he child becoming] an adult, except where a child becomes an adult during the pendency of proceedings in the Family Court” and 9 N.N.C. § 1156(H) which states that “[wjhen a child reaches 18 years of age all judgments affecting the child then in force automatically terminate.”

III

When this Court accepted this question for review on October 14, 2009, we stated our conclusion that the requirements established by Navajo Housing Authority v. Betsoi, 5 Nav. R. 5 (Nav.Sup.Ct.1984), were met. We now elaborate on our conclusion. In Betsoi, the Court made clear that certain elements must occur before a specific question of law may be sent from a lower to a higher court for a decision. The lower court must show that (a) the question is one of legal doubt requiring a final determination of law; (b) the question is a question of material importance or an issue of substantial public interest; (c) it may so affect the merits of the controversy that it ought to be determined by the reviewing court before further proceedings in the trial court; and (d) that the first three elements must be so determined to exist by the court before which the cause is pending prior to the question(s) being certified for review. Id. at 6-7.

First, we find that the plain language of the two statutes are clearly contradictory. The conflicting statutes unquestionably casts doubt whether or not the Court would have jurisdiction over the person who is now' 18 years old; therefore, a legal determination as to whether or not the underlying cases may continue or must be dismissed upon the minor child’s eighteenth birthday is needed. Second, the question goes to what court, if any, would have jurisdiction and whether the person should be treated as a minor or as an adult; both of these matters, of course, are questions of material importance and issues of substantial public interest. Whether or not a family court has continuing jurisdiction also determines whether the legislative purposes of the Children’s Code are effectuated. Third, the question affects, of course, what standard of proof and what sentence may be applied to the charges and to revocation of probation, and whether the charges will be adjudicated at all—all matters affect the adjudication of the merit s; therefore, the question ought to have been determined by this Court before further proceedings in the lower court. The fourth element requires a finding that the first three elements existed prior to the question being presented to this Court. It can be argued that the first three elements do not now [380]*380exist because the family court had dismissed the case (upon the release of the child at his 18th birthday) before this Court could accept the petition and decide the certified question. In other words, the need to answer the question became moot. On this point, we agree with the family court and hereby hold that in the limited situation where the factual circumstances necessitating an answer to a question are likely to arise again, this Court should still answer the question even if the underlying case has already been decided or the case has been dismissed in the lower court.1

In the matter at bar, the need to answer the certified question is capable of repetition because it is highly likely that there will be more young people turning 18 years old while they are facing proceedings in family court. Furthermore, an answer from this Court is needed to provide consistent treatment throughout the Nation. We therefore answer this question even if the underlying cases are dismissed. We now consider the question.

IV

The family court has exclusive original jurisdiction over all proceedings in which a child is alleged to be a child in need of supervision, dependent child, or a delinquent child. 9 N.N.C. § 1055(A). Jurisdiction is retained until terminated by the following situations:

1.

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

Related

Roe v. Wade
410 U.S. 113 (Supreme Court, 1973)
Tso v. Navajo Housing Authority
8 Navajo Rptr. 548 (Navajo Nation Supreme Court, 2004)
Bizardi v. Navajo Nation
8 Navajo Rptr. 593 (Navajo Nation Supreme Court, 2004)
Kesoli v. Anderson Security Agency
8 Navajo Rptr. 724 (Navajo Nation Supreme Court, 2005)
Goldtooth v. Naa Tsis' Aan Community School, Inc.
8 Am. Tribal Law 152 (Navajo Nation Supreme Court, 2009)
Watson v. Watson
8 Am. Tribal Law 361 (Navajo Nation Supreme Court, 2010)
Young v. Tribal Grievance Committee
1 Am. Tribal Law 539 (Sac and Fox Nation Supreme Court, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
8 Am. Tribal Law 377, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-certified-question-from-the-crownpoint-family-court-navajo-2010.