In Re Om Minor

CourtMichigan Court of Appeals
DecidedJune 11, 2025
Docket373430
StatusUnpublished

This text of In Re Om Minor (In Re Om 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 Om Minor, (Mich. Ct. App. 2025).

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UNPUBLISHED June 11, 2025 11:58 AM In re OM, Minor.

No. 373430 Genesee Circuit Court Family Division LC No. 22-138053-NA

Before: YATES, P.J., and YOUNG and WALLACE, JJ.

PER CURIAM.

Respondent-father appeals as of right the trial court’s order assuming jurisdiction over the minor child, OM, under MCL 712A.2(b)(1) and (2). For the reasons set forth in this opinion, we affirm the trial court’s order.

I. BACKGROUND AND PROCEDURAL HISTORY

In March 2022, petitioner, the Department of Health and Human Services (DHHS), filed a petition to remove OM and her siblings from their mother’s care based on reports of physical and emotional abuse, as well as their mother’s declining mental health.1 The trial court authorized DHHS’s petition and placed OM with respondent-father, her legal father.2 DHHS sought to make respondent-father a respondent in those proceedings because of his criminal record and history with CPS, but the trial court declined to do so. Respondent-father frequently expressed an unwillingness to care for OM and eventually placed her with his adult son. As OM’s mother progressed in her services, the trial court returned the children to her care. However, the court later removed the children again in January 2023 after OM and her sibling, ZM, disclosed that their mother’s boyfriend sexually abused them and that their mother was aware of the abuse. OM

1 The children’s mother is not a party to this appeal. 2 Respondent-father is not the father of any of OM’s siblings.

-1- was again placed in respondent-father’s care with the requirement that their mother only have supervised contact with OM and that their mother’s boyfriend have no contact with OM.

Several issues arose while OM was in respondent-father’s care. Respondent-father refused to bring OM to scheduled parenting-time visits with her mother, he refused to comply with subpoenas for OM to testify in her mother’s case, he refused to let OM participate in court-ordered therapy, and he refused to let DHHS caseworkers meet with OM. Respondent-father’s compliance with the court’s orders improved slightly after the court chastised respondent-father for his noncompliance, but this improvement was only temporary. Respondent-father again refused to let OM testify in her mother’s trial, he refused to let DHHS or OM’s court-appointed special advocate (CASA) meet with her, and he continued to keep OM out of therapy. DHHS again sought to make respondent-father a respondent in the child protective proceedings after it learned that respondent- father allowed OM’s mother and her boyfriend to have unsupervised visits with OM. Respondent- father also told OM’s CASA that he wanted OM returned to her mother’s care. The court authorized DHHS’s petition and allowed for in-home jurisdiction while reiterating to respondent- father the court’s orders.

The trial court removed OM from respondent-father’s care in June 2024 after OM’s caseworker and CASA reported concerns about OM’s well-being in respondent-father’s care. Respondent-father limited OM’s access to people outside his home, OM’s hair was matted and had mold in it, there were concerns about OM’s nutrition, and there were concerns about respondent-father’s temper with OM. Respondent-father still refused to let OM attend therapy, he refused to address OM’s educational needs, and he frequently stated that he would return OM to her mother even if the court terminated her parental rights to OM.

At respondent-father’s adjudication trial, the court heard testimony from OM’s caseworker and CASA about respondent-father’s noncompliance with the court’s orders, respondent-father’s refusal to address OM’s mental-health and educational needs, and OM’s demeanor around respondent-father after removal. Moreover, the court heard testimony that OM had “flourished” since her removal from respondent-father’s care, including that she was engaged in therapy and doing very well academically. While respondent-father testified that he provided for all of OM’s needs, OM’s fictive kin3 placement testified about OM’s concerning weight, appearance, demeanor, academic performance, and eating habits after DHHS removed her from respondent- father’s care. OM also testified that she was scared of respondent-father and scared that he would hit her, as he had threatened, when she got in trouble. She would often cry when in his care because she did not want to live with him. OM further testified that her hair was matted and had mold in it while living with him, and she had a “huge bump” that was bleeding because of how her hair was cared for. She said almost everything was better since she was removed from respondent- father’s care.

3 “Fictive kin” generally refers to a person who is at least 18 years old and who is not related to the child by blood, marriage, or adoption but who has a strong emotional connection or role in the child’s life or an infant child’s parent’s life so that the person is considered a “relative,” i.e., family. See MCL 712A.13a(1)(j)(ii).

-2- Following the hearing, the trial court entered an order of adjudication concluding that statutory grounds to exercise jurisdiction existed under MCL 712A.2(b)(1) and (2). In reaching its decision, the court considered the testimony presented by each of the witnesses and expressed its concern about respondent-father’s refusal to comply with the court’s orders or cooperate with DHHS and the CASA staff. In particular, the court considered respondent-father’s refusal to let DHHS or CASA staff meet with OM alone, his refusal to let OM participate in therapy, his refusal to discuss an Individualized Education Program (IEP) for OM, and his frequent statements about returning OM to her mother. The court was concerned that respondent-father did not believe OM’s allegations of sexual abuse and it was concerned about the changes in OM’s weight, demeanor, and hair while in respondent-father’s care. The trial court found that petitioner had met its burden by a preponderance of the evidence in light of respondent-father’s blatant disregard for court orders, his insistence on returning OM to respondent-mother, and OM’s physical and mental condition in his care. This appeal followed.

II. STANDARD OF REVIEW

We review a trial court’s decision to exercise jurisdiction for clear error in light of the court’s findings of fact. In re BZ, 264 Mich App 286, 295; 690 NW2d 505 (2004). “A finding is clearly erroneous if, although there is evidence to support it, we are left with a definite and firm conviction that a mistake has been made.” In re Long, 326 Mich App 455, 460; 927 NW2d 724 (2018) (quotation marks and citation omitted).

III. ANALYSIS

Respondent-father argues that the trial court clearly erred by finding that statutory grounds to exercise jurisdiction in his case existed by a preponderance of the evidence. We disagree.

The purpose of child protective proceedings is the protection of the child. In re Brock, 442 Mich 101, 107; 499 NW2d 752 (1993). “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, a trial court determines whether it may exercise jurisdiction over the child during the adjudicative phase. Id. During this phase, the petitioner bears the burden of proving by a preponderance of the evidence that one or more of the statutory grounds for exercising jurisdiction exist. See id.; see also MCR 3.972(C)(1); MCR 3.977(E)(2).

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Related

In Re BZ
690 N.W.2d 505 (Michigan Court of Appeals, 2005)
People v. Cross
760 N.W.2d 314 (Michigan Court of Appeals, 2008)
In Re Brock
499 N.W.2d 752 (Michigan Supreme Court, 1993)
in Re I M Long Minor
927 N.W.2d 724 (Michigan Court of Appeals, 2018)
In re Sanders
852 N.W.2d 524 (Michigan Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
In Re Om Minor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-om-minor-michctapp-2025.