In Re Doe

3 A.3d 657, 416 N.J. Super. 233
CourtNew Jersey Superior Court Appellate Division
DecidedAugust 5, 2010
DocketFG-06-23-10
StatusPublished

This text of 3 A.3d 657 (In Re Doe) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Doe, 3 A.3d 657, 416 N.J. Super. 233 (N.J. Ct. App. 2010).

Opinion

3 A.3d 657 (2010)
416 N.J. Super. 233

In the Matter of Noel DOE, a minor.

Docket No. FG-06-23-10

Superior Court of New Jersey, Chancery Division, Cumberland County, Family Part.

Decided August 5, 2010.

*659 Mara Spiegeland, Deputy Attorney General, for New Jersey Division of Youth and Family Services (Paula Dow, Attorney General, attorney).

Nicholas Jones, Law Guardian, attorney for minor.

MENDEZ, P.J.F.P.

The novel issues to be resolved in this case involve the scope and applicability of the New Jersey Safe Haven Infant Protection Act, N.J.S.A. 30:4C-15.5 to 15.11. The initial question is whether Noel Doe,[1] an infant who was delivered and then immediately surrendered by her mother, Jane Doe, in a hospital maternity ward, qualifies as a Safe Haven Baby. The Division of Youth and Family Services (hereinafter "the Division") filed a petition on January 5, 2010, seeking to terminate the parental rights of John and Jane Doe under the New Jersey Safe Haven Infant Protection Act. Upon careful consideration of the evidence presented, as well as an analysis of the legislative intent and public policy of the statute, the court finds that Noel Doe, the infant, was properly surrendered under the Safe Haven law. For all the reasons contained in this opinion, the Division's petition for termination of the parental rights of John and Jane Doe to Noel Doe is granted.

Factual Background

The child, Noel Doe, a girl, was born on December 16, 2009, at South Jersey Regional Medical Center in Vineland, New Jersey. The mother presented herself to the hospital in labor, was admitted to the maternity ward, and gave birth there. The hospital took her name and other identifying information as a delivering mother; however, the documents provided to the court in evidence redact her name or list her as "Unknown, Doe," as upon delivering her child, Jane told the workers at the hospital that she wished to surrender *660 her baby and requested anonymity. Jane was allowed to leave her baby at the hospital under Safe Haven protection and was discharged on December 17.

A social worker interviewed Jane prior to her discharge from the hospital and recorded the results of the interview on the confidential patient information form. The form indicates that Jane only spoke Spanish, and was provided with information about the Safe Haven law in Spanish. When interviewed by the Spanish speaking social worker, who came on a referral that Jane wished to place the baby for adoption, Jane repeatedly requested complete anonymity. Jane informed the social worker that she already had one child, and that the father of Noel had disappeared and was not in contact with her. Jane stated that she could not raise another child, especially with no help, and wished to give this child up for adoption. Jane was noted to be sad, but repeatedly requested to give the child up for adoption with complete anonymity and stressed that this was her own decision. Jane requested a discharge letter stating that she had miscarried the baby so she could tell her family that, instead of telling them that she had placed the baby for adoption. The social worker informed her that the hospital could not do this, but the doctor agreed to write her a medical leave letter for six weeks of maternity leave and to keep the letter very general and vague so as not to divulge the nature of the situation.

The information sheet notes on December 18 that there was some confusion as to whether Noel qualified as a Safe Haven baby because Jane had actually given birth in the hospital and then asked for Safe Haven anonymity. The information sheet noted that at one point hospital lawyers had told staff that Jane would have to return to the hospital, receive the baby, and then either deliver the baby to a police station or the hospital emergency room, which was on the premises, in order to qualify for Safe Haven. To that end, the social worker called Jane and told her that she needed to come to the hospital right away. The social worker collected funds to send a cab to Jane's home to bring her to the hospital after Jane agreed to come back, but when the cab went to the home, no one came out. The hospital then informed the Division on December 18 that Jane had given birth in the hospital and expressed an intent to leave the child at the hospital and not return for her pursuant to the Safe Haven law. The Division worker came and took custody of the child.

Noel has been placed in a Division-approved resource home and appears to be a healthy baby. Her resource parents have expressed a wish to adopt her. The hospital has redacted Jane Doe's identifying information from their records. The Division has accepted Noel as a Safe Haven infant. No notice has been given to Jane or John Doe of any of the proceedings regarding Noel Doe. The Division is seeking guardianship of Noel Doe with a permanent plan of adoption by the current caretaker.

Legal Analysis

Safe Haven Background

N.J.S.A. 30:4C-15.7 to 15.11, otherwise known as the New Jersey Safe Haven Infant Protection Act, became law on August 7, 2000. New Jersey and several other states passed similar laws around the same time, responding to a sixty-two-percent increase in the incidence of infant abandonment between 1991 and 1998, and several high profile cases of infant abandonment in which the infants were found dead. New Jersey was the fifth state to pass such a law. New Jersey's Safe Haven law has proven quite successful. Through the end of 2009, forty-three infants had been surrendered under the law. *661 Indeed, in the twelve months before Safe Haven was passed, eight babies were found abandoned in public places; in the twelve months following Safe Haven's enactment, there were only two.[2]

The three main principles behind Safe Haven are safety for the child, anonymity, and immunity from prosecution for the biological parents. In passing the Safe Haven law, the New Jersey Legislature found that "New Jersey and the nation have experienced sorrow in the knowledge that newborn infants are sometimes abandoned in life-threatening situations and that some of these children have been harmed or have died as a consequence of their abandonment." N.J.S.A. 30:4C-15.6(a). The Legislature acknowledged that parents of unwanted infants are often under severe emotional stress and that they may need a safe way to surrender their children to prevent them from putting the infants in dangerous or life-threatening situations. N.J.S.A. 30:4C-15.6(b). The Legislature noted that "[a]nonymity, confidentiality, and freedom from prosecution may encourage the parent to leave an infant safely and save the life of the infant." N.J.S.A. 30:4C-15.6(c). The legislative findings concluded that "this legislation is worthwhile if it saves even one infant's life." N.J.S.A. 30:4C-15.6(e). These legislative findings provide this court with the backdrop to determine the legislative intent in the construction of the New Jersey Safe Haven law.

Statutory Considerations

N.J.S.A.

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Related

G.S. v. Department of Human Services
723 A.2d 612 (Supreme Court of New Jersey, 1999)

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Bluebook (online)
3 A.3d 657, 416 N.J. Super. 233, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-doe-njsuperctappdiv-2010.