In Re N J Moore Minor

CourtMichigan Court of Appeals
DecidedMay 15, 2026
Docket372195
StatusUnpublished

This text of In Re N J Moore Minor (In Re N J Moore 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 N J Moore Minor, (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UNPUBLISHED May 15, 2026 1:10 PM In re N. J. MOORE, Minor.

No. 372195 Wayne Circuit Court Family Division LC No. 2019-000805-NA

Before: FEENEY, P.J., and GARRETT and BAZZI, JJ.

PER CURIAM.

Respondent-father appeals as of right the trial court’s order terminating his parental rights to the minor child, NJM, under MCL 712A.19b(3)(b)(ii) (parent failed to prevent abuse or injury), (b)(iii) (abuse or injury caused by nonparent adult), (c)(i) (conditions that led to adjudication continue to exist) and (ii) (failure to rectify other conditions), and (j) (reasonable likelihood of harm if returned to parent). We affirm.

I. BASIC FACTS AND PROCEDURAL HISTORY

The trial court originally took jurisdiction over NJM after a domestic violence incident occurred between respondent and NJM’s mother in NJM’s presence. The parental rights of NJM’s mother were terminated in 2022.1 Respondent was ordered to participate in individual counseling with an anger management component, maintain suitable housing and an income, and participate in weekly visits with NJM. On July 31, 2023, the trial court found that respondent had made enough progress on his treatment plan to return NJM to his care on August 2, 2023. On August 16, 2023, respondent called NJM’s maternal grandmother asking her to pick up NJM because respondent needed a break. When NJM’s grandmother changed NJM’s clothes the next morning, she noticed wounds on NJM’s inner arm and thighs. NJM’s grandmother took him to the hospital,

1 NJM’s mother appealed the termination order in Docket No. 362220. This Court dismissed the appeal on the parties’ stipulation. In re N J Moore, unpublished order of the Court of Appeals, entered November 22, 2022 (Docket No. 362220).

-1- and the physician thought that the wounds were consistent with cigarette burns and looked to be five to seven days old. NJM was removed from respondent’s care and the foster-care worker filed a supplemental petition for termination of respondent’s parental rights. Respondent entered a no- contest plea to the allegations in the supplemental petition. At the best-interest hearing, the trial court found that termination was in NJM’s best interests. This appeal followed.

II. INEFFECTIVE ASSISTANCE OF COUNSEL

Respondent argues that he was denied the effective assistance counsel when trial counsel advised him to enter a no-contest plea to the statutory grounds for termination and failed to present a defense during the best-interest hearing. We disagree.

To preserve a claim of ineffective assistance of counsel, the party asserting the error must raise the claim in a motion for a new trial or request for a Ginther2 hearing. People v Jackson (On Reconsideration), 313 Mich App 409, 431; 884 NW2d 297 (2015).3 Respondent did not raise this claim in a motion for a new trial or a request for a Ginther hearing. Consequently, our “review is limited to mistakes apparent from the record.” People v Miller, 326 Mich App 719, 726; 929 NW2d 821 (2019).

A claim of ineffective assistance of counsel involves mixed questions of law and fact. In re Casto, 344 Mich App 590, 610; 2 NW3d 102 (2022). A trial court’s findings of fact, if any, are reviewed for clear error. Id. But whether the facts constitute a violation of the respondent’s right to the effective assistance of counsel is a question of law that this Court reviews de novo. Id.

“To be constitutionally effective, counsel’s performance must meet an objective standard of reasonableness . . . .” In re Casto, 344 Mich App at 611 (quotation marks and citation omitted). In order to establish ineffective assistance of counsel, “the [respondent] must show that counsel’s performance fell short of this objective standard of reasonableness and that there is a reasonable probability that, but for counsel’s deficient performance, the outcome of [respondent’s] trial would have been different.” Id. at 611-612 (quotation marks and citation omitted; alterations in original). “A reasonable probability is a probability sufficient to undermine confidence in the outcome.” People v Randolph, 502 Mich 1, 9; 917 NW2d 249 (2018) (quotation marks and citation omitted). A respondent must meet a heavy burden to overcome the presumption that trial counsel employed an effective trial strategy. In re Casto, 344 Mich App at 612. Additionally, this Court will not “substitute its judgment for that of counsel’s on matters of litigation strategy, and counsel’s performance must be judged based on the knowledge, expertise, and information reasonably available when counsel formulated and implemented the litigation strategy.” Id.

Respondent argues that counsel’s performance fell below an objective standard of reasonableness when counsel advised respondent to enter a no-contest plea to the statutory grounds

2 People v Ginther, 390 Mich 436; 212 NW2d 922 (1973). 3 “The principles applicable to claims of ineffective assistance of counsel in the arena of criminal law also apply by analogy in child protective proceedings . . . .” In re Martin, 316 Mich App 73, 85; 896 NW2d 452 (2016).

-2- for termination. Respondent specifically argues that trial counsel was ineffective for advising him to stipulate that, at adjudication, he severely beat NJM’s mother causing injuries requiring stitches because the trial court never made such a finding. Respondent correctly argues that the record did not support this factual basis for the plea. When the trial court took jurisdiction over NJM, the trial court found that there was one incident of domestic violence involving NJM’s mother “where there was actually some harm.” The trial court accepted that NJM’s mother required stitches but questioned how NJM’s mother had been injured and wondered if she had stumbled and fallen down after drinking excessively. Because this stipulation did not adequately reflect the trial court’s findings, trial counsel’s agreement to this stipulation in support of the plea was objectively unreasonable. Additionally, the trial court’s original finding was part of the record, and agreeing to this stipulation did nothing to advance respondent’s reason for entering a plea, namely, to avoid criminal or civil liability.

However, respondent has failed to establish a reasonable probability that but for this stipulation, the outcome of the hearing would have been different. The trial court was aware of its previous findings as it stated during the best-interest hearing that it had previously denied a request to terminate respondent’s parental rights and offered respondent the opportunity to regain custody. Furthermore, the court found that termination was in NJM’s best interests because NJM had not suffered any nonaccidental injuries until he was returned to respondent’s care. The trial court also emphasized respondent’s failure to visit NJM in nine months because of the inconvenience of his transportation issues. Accordingly, respondent failed to establish that he was denied effective assistance of counsel because of the stipulation regarding NJM’s mother.

Respondent next argues that allowing respondent to make admissions regarding the nature of NJM’s injuries was not a sound strategic decision considering respondent’s denial that he caused the injuries. In this instance, the parties stipulated that the burns were not accidental. The parties also stipulated to the admission of medical records from Eastpointe Urgent Care detailing NJM’s injuries and the physician assistant’s conclusion that the injuries were not accidental, but consistent with cigarette burns.

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Related

People v. Kaczorowski
475 N.W.2d 861 (Michigan Court of Appeals, 1991)
People v. Ginther
212 N.W.2d 922 (Michigan Supreme Court, 1973)
People v. Jackson (On Reconsideration)
884 N.W.2d 297 (Michigan Court of Appeals, 2015)
People of Michigan v. David Joseph Miller
929 N.W.2d 821 (Michigan Court of Appeals, 2019)
In re Olive/Metts Minors
823 N.W.2d 144 (Michigan Court of Appeals, 2012)
In re Frey
297 Mich. App. 242 (Michigan Court of Appeals, 2012)
In re Tiemann
297 Mich. App. 250 (Michigan Court of Appeals, 2012)
In re Martin
896 N.W.2d 452 (Michigan Court of Appeals, 2016)
People v. Randolph
917 N.W.2d 249 (Michigan Supreme Court, 2017)

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Bluebook (online)
In Re N J Moore Minor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-n-j-moore-minor-michctapp-2026.