In Re Fernald Minors

CourtMichigan Court of Appeals
DecidedFebruary 23, 2026
Docket375421
StatusUnpublished

This text of In Re Fernald Minors (In Re Fernald Minors) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Fernald Minors, (Mich. Ct. App. 2026).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

UNPUBLISHED February 23, 2026 11:51 AM In re FERNALD, Minors.

No. 375421 Wayne Circuit Court Family Division LC No. 2017-000682-NA

Before: GADOLA, C.J., and REDFORD and RICK, JJ.

PER CURIAM.

In this child protective proceeding, respondent-appellant-mother appeals as of right the trial court’s order assuming jurisdiction over the minor children, COF, DAF, HIF, and JAF, under MCL 712A.2(b)(1) and (b)(2). We affirm.

I. BASIC FACTS AND PROCEDURAL HISTORY

In March 2024, Children’s Protective Services (“CPS”) received a complaint alleging that the children’s father, Darryl Fernald, abused respondent by attempting to forcibly take respondent’s cell phone to sell for drug money.1 Fernald was alleged to have leaned against respondent’s broken legs, spit in her face, and thrown an alcoholic beverage in her face during the incident. HIF witnessed the incident and was splashed in the face when Fernald threw the beverage. It was further alleged that Fernald pushed HIF, causing her to fall to the floor. During its investigation of the incident, CPS learned of allegations that respondent’s legs were previously broken in February 2024 in an incident in which respondent climbed on top of the hood of a van driven by Fernald and he slammed on the brakes causing respondent to fly off the vehicle.

In April 2024, CPS received a second complaint involving a new report of domestic violence at the end of March 2024. It was alleged that Fernald entered respondent’s home without permission, argued with her, and threatened to burn down her house if she called the police on

1 The children’s father is not a party to this appeal.

-1- him. Police officers responded to the incident and observed that respondent’s house was a “hoarder house” filled with “random junk” and a “fire hazard.” Finally, another instance of domestic violence was alleged to have occurred when Fernald entered respondent’s home uninvited and pressured her to drop criminal charges against him. When respondent refused, Fernald grabbed her face and squeezed her foot through her cast as she sat in a wheelchair.

In May 2024, the Department of Health and Human Services (“the DHHS”) filed a petition requesting removal of the children from respondent and Fernald’s care and requesting termination of their parental rights. The petition alleged it was contrary to the welfare of the children to remain in respondent’s and Fernald’s care because of an “unreasonable risk of harm due to domestic violence, unfit housing and physical neglect.” The petition further detailed the parents’ extensive history of CPS contact, including an emergency removal in 2017 because of physical neglect, home conditions, and domestic violence.

A preliminary hearing was held in June 2024 at which a referee found it was contrary to the welfare of the children to remain in the home and the children were placed in foster care. The referee adjourned the probable-cause portion of the hearing so that the DHHS could contact several tribes to determine whether the children had Indian heritage.2 Both parents appealed the order removing the children. In In re Fernald, unpublished per curiam opinion of the Court of Appeals, issued April 14, 2025 (Docket Nos. 372395 and 372397), a panel of this Court affirmed the order removing the children from their parents’ care.

After the children’s removal, the DHHS filed a supplemental petition requesting that the trial court exercise jurisdiction over the minor children under MCL 712A.2(b)(1) and (b)(2); and terminate respondent’s and Fernald’s parental rights pursuant to MCL 712A.19b(3)(g) (failure to provide proper care and custody) and (3)(j) (reasonable likelihood that the children will be harmed if returned to the parent). Respondent made a judge demand pursuant to MCR 3.912 and an adjudication trial was held on February 11, 2025. At the trial, the trial court heard testimony from three witnesses—respondent, Fernald, and CPS Investigator Vereea Boatman. The trial court determined that it was proper to exercise jurisdiction over the minor children pursuant to MCL 712A.2(b)(1) and (b)(2) on the basis of the parents’ history of domestic violence, Fernald’s substance abuse history, and the family’s history of previous CPS involvement. However, the trial court held that termination of respondent’s and Fernald’s parental rights was premature. This appeal followed.

II. STANDARD OF REVIEW

“To properly exercise jurisdiction, the trial court must find that a statutory basis for jurisdiction exists.” In re BZ, 264 Mich App 286, 295; 690 NW2d 505 (2004). “We review the trial court’s decision to exercise jurisdiction for clear error in light of the court’s findings of fact[.]” Id. “A finding is clearly erroneous if although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been made.” In re COH, ERH, JRG, & KBH, 495 Mich 184, 203-204; 848 NW2d 107 (2014) (quotation marks and citation omitted). “Thus, under the clear-error standard, a reviewing court should not

2 It was later determined that none of the children had Indian heritage.

-2- substitute its judgment on questions of fact unless the factual determination clearly preponderates in the opposite direction.” Id. at 204 (quotation marks and citation omitted).

III. ANALYSIS

As an initial matter, we note that respondent’s argument on appeal is insufficiently briefed and unclear such that it is not apparent to this Court exactly what assertion of error she raises. Her appellate briefing refers to error in both the removal of the children and the trial court’s decision to assume jurisdiction. Her citation to authority is unhelpful because her briefing includes only one substantive citation without elaboration to In re Benavides, 334 Mich App 162; 964 NW2d 108 (2020), for the proposition that when a child is placed in foster care “it is contrary to the welfare of the child to remain at home and reasonable efforts to prevent removal are not required.” As previously noted, the children were removed on June 11, 2024, before the adjudication trial. Both respondent and Fernald have already appealed the removal of the children and a panel of this Court has affirmed the trial court’s order of removal based on the extensive history of domestic violence and previous involvement with CPS. In re Fernald, unpub op at 1. Because a panel of this Court has already addressed removal and respondent appeals from the trial court’s order assuming jurisdiction, we treat this as an appeal of the trial court’s decision to assume jurisdiction over the children.

On appeal, respondent contends that the trial court clearly erred by assuming jurisdiction because Fernald was no longer in the home, which eliminated the threat of domestic violence against respondent, Fernald never abused the children, and respondent had a clean and safe home. We disagree.

“In Michigan, child protective proceedings comprise two phases: the adjudicative phase and the dispositional phase.” In re Sanders, 495 Mich 394, 404; 852 NW2d 524 (2014). Generally, the trial court determines whether it can take jurisdiction over the children in the adjudicative phase. Id. To properly exercise jurisdiction, the trial court must find, by a preponderance of the evidence, that at least one statutory basis for jurisdiction under MCL 712A.2(b) exists. In re Miller, 347 Mich App 420, 424; 15 NW3d 287 (2023).

The trial court in this case took jurisdiction over all four children under MCL 712A.2 which provides in relevant part:

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Related

In Re BZ
690 N.W.2d 505 (Michigan Court of Appeals, 2005)
In Re HRC
781 N.W.2d 105 (Michigan Court of Appeals, 2009)
Wright v. Wright
761 N.W.2d 443 (Michigan Court of Appeals, 2008)
In re COH
848 N.W.2d 107 (Michigan Supreme Court, 2014)
In re Sanders
852 N.W.2d 524 (Michigan Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
In Re Fernald Minors, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-fernald-minors-michctapp-2026.