In Re G Vanderark Minor

CourtMichigan Court of Appeals
DecidedSeptember 19, 2024
Docket369645
StatusUnpublished

This text of In Re G Vanderark Minor (In Re G Vanderark Minor) 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 G Vanderark Minor, (Mich. Ct. App. 2024).

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UNPUBLISHED September 19, 2024

In re G. VANDERARK, Minor.

No. 369645 Muskegon Circuit Court Family Division LC No. 22-003142-NA

Before: N. P. HOOD, P.J., and O’BRIEN and REDFORD, JJ.

PER CURIAM.

In this case arising from a child protective proceeding, respondent-mother appeals by right the trial court’s order terminating her parental rights to the minor child, GV. The trial court terminated respondent’s parental rights under MCL 712A.19b(3)(b)(i), (b)(ii), (c)(i), (c)(ii), (h), (j), (k), and (m). On appeal, respondent claims that the trial court abused its discretion when it admitted gruesome images and videos depicting the condition of, as well as respondent’s treatment of, her 15-year-old son, TF, whom she was convicted of abusing and murdering. She further claims that the evidence did not support the trial court’s findings that the Department of Health and Human Services (the Department) established grounds for termination by clear and convincing evidence or that termination was in GV’s best interests. We conclude that respondent has not identified any errors and accordingly affirm.

I. BASIC FACTS

Respondent had four children from a previous relationship. TF was one of those children. Respondent and her first husband divorced, and respondent subsequently married a man named Adam. Respondent and Adam had GV in 2014. Respondent’s adult son, Paul, came to live with respondent, Adam, and GV in May 2020 after Paul’s father (respondent’s ex-husband) kicked Paul out. Respondent’s ex-husband sent TF to live with respondent in May 2021. TF had autism spectrum disorder, attention deficit hyperactivity disorder, and bipolar disorder. According to respondent, her ex-husband sent TF to live with her because her ex-husband could no longer handle TF’s behaviors.

-1- Adam suffered a stroke in January 2022. Because he could no longer care for himself, Adam went to live with his parents. He had hoped to return to his home with respondent after rehabilitation. Adam died during the pendency of these proceedings.

On July 6, 2022, respondent called 911 and reported that TF was not breathing. Emergency responders pronounced TF dead upon their arrival. They discovered that TF was emaciated and saw bruising on his torso. Respondent told emergency responders that TF had been on a hunger strike.

The Department investigated the circumstances surrounding TF’s death and removed GV from respondent’s care. The Department petitioned to terminate respondent’s parental rights in July 2022. Respondent pleaded no contest to allegations that established jurisdiction in May 2023. The parties agreed to postpone the termination hearing until after respondent’s criminal trial related to TF’s death.

A jury convicted respondent of felony murder in relation to TF’s death in December 2023. The trial court held a termination hearing over two days in January 2024. The trial court heard testimony and considered evidence detailing horrific abuse that respondent inflicted on TF and heard testimony about how that abuse affected GV. At the conclusion of the hearing, the trial court found that the Department had proved the identified grounds for terminating respondent’s parental rights and found that termination was in GV’s best interests. The trial court then entered an order terminating respondent’s parental rights.

Respondent now appeals by right.

II. GRUESOME IMAGES AND VIDEOS

Respondent first argues that the trial court erred when it denied her motion in limine to preclude the Department from admitting images of TF when he was found dead and admitting video clips that depicted TF’s last hours.

A. STANDARD OF REVIEW

This Court reviews for an abuse of discretion a trial court’s evidentiary decisions. People v McFarlane, 325 Mich App 507, 517; 926 NW2d 339 (2018). A trial court abuses its discretion when it selects an outcome that falls outside the range of principled outcomes. See In re Utrera, 281 Mich App 1, 15; 761 NW2d 253 (2008). This Court reviews de novo whether the trial court properly applied the rules of evidence. McFarlane, 325 Mich App at 517. A trial court necessarily abuses its discretion when it admits evidence that is inadmissible as a matter of law. Id.

B. ANALYSIS

Because the Department requested termination at the initial disposition on the basis of aggravated circumstances, see MCL 722.638(2), the trial court had to order termination of respondent’s parental rights if it found, among other things, that the Department proved by clear and convincing legally admissible evidence one or more specified grounds for termination, see MCR 3.977(E)(3). The rules of evidence provide that relevant evidence is admissible unless

-2- excluded by the Constitutions of the United States or Michigan, by the rules of evidence, or by other rules prescribed by the Supreme Court. See MRE 402. Evidence is relevant if it has any tendency to make a fact that is of consequence to the action more or less probable than it would be without the evidence. MRE 401.

On appeal, respondent does not argue that the images or videos were irrelevant; she argues instead that—even though relevant—the trial court should have excluded the images under MRE 403 because they were too gruesome to be fairly considered. MRE 403 provides that a trial court has discretion to exclude otherwise admissible evidence “if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.” A trial court may not exclude evidence under MRE 403 simply because it is prejudicial; the rule only provides for the exclusion of evidence that is unfairly prejudicial. People v McGhee, 268 Mich App 600, 607; 709 NW2d 595 (2005). “Evidence is unfairly prejudicial when there exists a danger that marginally probative evidence will be given undue or preemptive weight by the jury.” People v Crawford, 458 Mich 376, 398; 582 NW2d 785 (1998).

In this case, the Department sought to prove several grounds for terminating respondent’s parental rights that involved proof of how she treated GV’s sibling, TF. Under MCL 712A.19b(3)(b), the Department had to prove, in relevant part, that respondent either physically injured TF or that she had the opportunity to prevent TF from suffering an injury and failed to prevent the injury. The Department also sought to prove that respondent abused TF and, in relevant part, that the abuse amounted to torture, severe physical abuse, murder, or aiding and abetting murder, as provided under MCL 712A.19b(3)(k). Similarly, the Department sought to prove that respondent was convicted of murdering TF, and that—under the circumstances— termination would be in GV’s best interests as provided under MCL 712A.19b(3)(m). Because the nature and extent of respondent’s mistreatment of TF was an element of each of these grounds for termination, the Department had the right to offer all relevant evidence to prove that element, even if respondent did not dispute the element. See People v Mills, 450 Mich 61, 70-71; 537 NW2d 909 (1995). The Department could also present evidence concerning how respondent treated TF to prove how she might treat GV under the doctrine of anticipatory neglect. See In re Kellogg, 331 Mich App 249, 258-259; 952 NW2d 544 (2020).

The Department presented extensive evidence that respondent orchestrated and actively participated in a weeks-long campaign of torturing and starving TF.

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Related

In Re Mason
782 N.W.2d 747 (Michigan Supreme Court, 2010)
People v. Vasher
537 N.W.2d 168 (Michigan Supreme Court, 1995)
People v. McGhee
709 N.W.2d 595 (Michigan Court of Appeals, 2006)
In Re Utrera
761 N.W.2d 253 (Michigan Court of Appeals, 2008)
People v. Crawford
582 N.W.2d 785 (Michigan Supreme Court, 1998)
People of Michigan v. Anthony Ray McFarlane Jr
926 N.W.2d 339 (Michigan Court of Appeals, 2018)
People v. Mills
537 N.W.2d 909 (Michigan Supreme Court, 1995)
In re Moss
836 N.W.2d 182 (Michigan Court of Appeals, 2013)
In re White
846 N.W.2d 61 (Michigan Court of Appeals, 2014)

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In Re G Vanderark Minor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-g-vanderark-minor-michctapp-2024.