In re: J.H.

152 Haw. 373
CourtHawaii Supreme Court
DecidedMarch 15, 2023
DocketSCWC-21-0000316
StatusPublished

This text of 152 Haw. 373 (In re: J.H.) is published on Counsel Stack Legal Research, covering Hawaii 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: J.H., 152 Haw. 373 (haw 2023).

Opinion

*** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

Electronically Filed Supreme Court SCWC-XX-XXXXXXX 15-MAR-2023 08:07 AM Dkt. 30 OP

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

---o0o---

IN THE INTEREST OF JH

SCWC-XX-XXXXXXX

CERTIORARI TO THE INTERMEDIATE COURT OF APPEALS (CAAP-XX-XXXXXXX; FC-S NO. 18-00251)

MARCH 15, 2023

RECKTENWALD, C.J., NAKAYAMA, McKENNA, AND EDDINS, JJ.; AND WILSON, J., DISSENTING 1

OPINION OF THE COURT BY EDDINS, J.

At the start of this Child Protective Act case, the Family

Court of the First Circuit appointed attorneys for a mother and

father (Parents). Then, when Parents failed to appear at a

court hearing, the court discharged counsel. Later, Parents

reappeared, the court reappointed counsel, and the case

1 At the time of this opinion’s publication, Justice Wilson’s dissent is forthcoming. *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

progressed. After a trial, the family court terminated Parents’

parental rights.

Because the family court discharged Parents’ counsel before

the case had ended, the Intermediate Court of Appeals (ICA)

ruled that structural error occurred. It ordered a new trial.

A family court must timely appoint counsel in parental

rights cases. Otherwise, structural error will nullify an

outcome adverse to a parent. But the appointment, discharge,

and reappointment of counsel is different.

We hold that if the family court appoints counsel at the

onset of a parental rights case, and later there’s a break in

representation due to a parent’s voluntary absence, then there

is no structural error. As long as a fundamentally fair

procedure ensues and due process is satisfied, the family

court’s decision will stand.

I.

JH was born in October 2018. Soon after his birth, the

Department of Human Services (DHS) assumed custody of JH under

the Child Protective Act, Hawaiʻi Revised Statutes (HRS) §§ 587A-

8 and 587A-9. 2 Then DHS petitioned for temporary foster custody.

2 At birth, JH tested positive for unprescribed opiates. While hospitalized in the Neonatal Intensive Care Unit at Kapi‘olani Medical Center, JH was taken into police protective custody. See HRS § 587A-8 (2018):

(a) A police officer shall assume protective custody of a child without a court order and without the consent of the

2 *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

The family court appointed counsel for both parents at the

first hearing on DHS’s petition.

In July 2019, at a continued hearing, the court ordered

Mother and Father to appear at a further hearing in 20 days.

The court cautioned Parents: if they didn’t appear on that date,

child’s family, if in the discretion of the police officer, the officer determines that: (1) The child is subject to imminent harm while in the custody of the child’s family; . . . . (4) The child’s parent has subjected the child to harm or threatened harm and the parent is likely to flee with the child. (b) The department shall assume temporary foster custody of the child when a police officer has completed the transfer of protective custody of the child to the department as follows: . . . . (2) If the child is or will be admitted to a hospital or similar institution, the police officer shall immediately complete the transfer of protective custody to the department by notifying the department and receiving an acknowledgment from the hospital or similar institution that it has been informed that the child is under the temporary foster custody of the department.

Then, under HRS § 587A-9 (2018), DHS assumed temporary foster custody of JH.

(a) When the department receives protective custody of a child from the police, the department shall: (1) Assume temporary foster custody of the child if, in the discretion of the department, the department determines that the child is subject to imminent harm while in the custody of the child’s family; [and] . . . . (5) Within three days, excluding Saturdays, Sundays, and holidays: (A) Relinquish temporary foster custody, return the child to the child’s parents, and proceed pursuant to section 587A-11(4), (5), or (6); (B) Secure a voluntary placement agreement from the child’s parents to place the child in foster care, and proceed pursuant to section 587A-11(6) or (8); or (C) File a petition with the court.

3 *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

August 14, then the court could order a default judgment, decide

the petition, and award foster custody of JH to DHS.

Neither parent showed on August 14, 2019. The court

entered default judgments against Parents, waived their notice

of future hearings, and discharged their counsel effective

August 31, 2019. 3 The court advised counsel that if Parents

contacted them, then counsel could file an ex parte motion to

rescind the discharge order. The court also ordered the parents

to appear at a periodic review hearing on January 21, 2020.

One week before the scheduled periodic review hearing, DHS

moved to terminate Mother and Father’s parental rights. The

court scheduled this motion on the date of the periodic review

hearing.

Mother and Father appeared on January 21, 2020. So did

counsel. 4 Parents requested a trial on DHS’s motion to terminate

parental rights. Due to COVID-19 concerns and scheduling

conflicts, the court continued the trial date several times.

3 The Honorable Brian A. Costa presided.

4 Parents appeared with their counsel at the periodic review hearing before the Honorable John C. Bryant. Nothing in the record, however, reflects that the court reappointed counsel. There is also nothing in the record – order-wise or otherwise - to reflect that Parents moved to set aside their default. Instead, the proceedings just resumed as if the court had not discharged Parents’ attorneys and defaulted Parents. The family court and all parties - Mother, Father, DHS, and JH’s Guardian Ad Litem - proceeded as if Parents’ counsel had been reappointed. This opinion likewise treats Parents’ appearance with their attorneys as a reappointment of counsel.

4 *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

The trial on DHS’s motion to terminate parental rights

began nearly a year later, on January 7, 2021. 5 Trial also

happened on February 4, 2021 and March 30, 2021. The parents,

represented by counsel, appeared each day of their trial.

On April 26, 2021, the family court granted DHS’s motion.

The court terminated Mother and Father’s parental rights. It

awarded DHS permanent custody of JH. The court made the

necessary findings under HRS § 587A-33(a). 6 It also issued a

termination of parental rights order, letters of permanent

custody, and Findings of Fact and Conclusions of Law.

Parents appealed. The ICA ordered supplemental briefing.

It asked the parties to brief whether its holding in In the

Interest of J.M. and Z.M., 150 Hawaiʻi 125, 497 P.3d 140 (App.

2021) applied. That is, does the discharge of counsel during

parental rights proceedings violate a parent’s due process

rights and amount to structural error?

5 The Honorable Andrew T.

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Cite This Page — Counsel Stack

Bluebook (online)
152 Haw. 373, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jh-haw-2023.