In re the Guardianship & Custody of Paul C.

21 Misc. 3d 864
CourtNew York City Family Court
DecidedOctober 9, 2008
StatusPublished
Cited by1 cases

This text of 21 Misc. 3d 864 (In re the Guardianship & Custody of Paul C.) is published on Counsel Stack Legal Research, covering New York City Family Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Guardianship & Custody of Paul C., 21 Misc. 3d 864 (N.Y. Super. Ct. 2008).

Opinion

OPINION OF THE COURT

W. Dennis Duggan, J.

The issue to be determined in this case is whether a grandmother, with Family Court Act article 6 custody, may directly file a termination of parental rights (TPR) petition, based on severe abuse, against a father who has murdered the mother. Social Services Law § 384-b (3) (b) provides that a TPR proceeding may be originated “by a relative with care and custody of the child” (emphasis added). Despite what appears to be a clear legislative direction, the court holds that this grandmother has no standing to file a TPR.

The maternal grandmother has filed a petition pursuant to Social Services Law § 384-b to terminate the father’s parental rights. She alleges, and it is beyond dispute, that the father murdered the mother of his child. After a jury trial, the father was convicted of reckless manslaughter in the second degree in violation of Penal Law § 125.15 (1). Because of this, the grandmother claims that the child is severely abused, a permitted ground for the termination of parental rights. She seeks summary judgment.

Family History

The 5 V2-year-old child in this case is the son of Paul C., Sr. and Cassandra K. Cassandra disappeared on May 22, 2004. Her skeletal remains were found in October 2004, dumped in a shallow grave near the Normanskill, a stream that marks the southern boundary of the City of Albany. After a four-month investigation, Paul C., Sr. was charged with intentional murder and depraved indifference murder. After a jury trial, he was convicted of second degree manslaughter and sentenced to a term of 5 to 15 years. Police records show that the father and his confederate drove around Albany purchasing a shovel, rope and work gloves while the mother’s body [866]*866was stuffed in his trunk. The sentencing minutes reveal that the father spent four minutes strangling the life out of the mother. The father has been incarcerated since his arrest four years ago.

Procedural History

The grandmother was awarded full custody, on consent, in June 2004. In November 2006, a second consent order permitted the father to communicate with the child by cards and letters.

Discussion

Social Services Law § 384-b sets forth the predicates and procedures for the termination of parental rights. In summary, parental rights may be terminated because of a parent’s mental illness, abandonment, permanent neglect, or severe or repeated abuse of the child. A predicate for the first three grounds is that the child must have been in the continuous care of the social service agency for at least six months in the case of abandonment and 12 months for permanent neglect and mental illness or retardation cases (these terms are defined in Social Services Law § 384-b [5], [6], [7] and [8]). In this decision, we will examine the predicates for a TPR proceeding that is based on severe abuse.

Section 384-b (8) (a) (iii) defines severe abuse as the homicide of one parent by the other parent. There is no dispute in this case that the father was convicted of manslaughter in the second degree in violation of section 125.15 of the Penal Law in that he recklessly killed the mother. This being one of the enumerated forms of homicide contained in Social Services Law § 384-b, there is no question of fact on this issue; the child has been severely abused by the father.

Even though a child has been severely abused by a parent, there is a condition precedent that must be met before a termination of parental rights determination may be entered by the court. Social Services Law § 384-b (8) (a) (iv) requires that the agency must have made “diligent efforts to encourage and strengthen the parental relationship, including efforts to rehabilitate the respondent, when such efforts will not be detrimental to the best interests of the child and such efforts have been unsuccessful and are unlikely to be successful in the [867]*867foreseeable future.”1 However, there is an escape clause from this requirement. Diligent efforts are not required if the “court has previously determined . . . that reasonable efforts to make it possible for the child to return to the safety of his home are not required” (Social Services Law § 384-b [8] [a] [iv] [emphasis added]).

This legislative scheme needs a bit of explanation. In the context of this particular section of law, there is no apparent plain English difference between “diligent efforts” and “reasonable efforts.” However, these efforts, are directed at achieving different goals. The “reasonable efforts” expended by the agency must be directed at the return of the child to his home. The “diligent efforts” of the agency must be directed at strengthening the parental relationship and rehabilitating the parent.2 It is clear that the Legislature has mandated that before a finding of severe abuse can be achieved, the agency must expend both reasonable efforts and diligent efforts in an attempt to achieve both stated goals — unless the agency avails itself of the escape clause. The escape clause permits the agency to apply under Family Court Act § 1039-b to seek a determination that reasonable efforts are not required.3 It is also clear that the law requires that the agency must perform these tasks and not a foster parent or another relative with whom the child is placed under article 10 or a relative with custody obtained under article [868]*8688. It is also clear that in this case the agency has made neither reasonable nor diligent efforts because it never filed an abuse petition against the father to put those mandates into play. Because no abuse or neglect petition was ever filed by the agency pursuant to Family Court Act § 1031, there has never been a request made for the court to determine that reasonable efforts were not required pursuant to Family Court Act § 1039-b (a). It is clear that a section 1039-b finding of no need for reasonable efforts can only be made pursuant to a petition filed under section 1031.

Based on the legislative scheme described above, it is clear that the grandmother may not proceed with a TPR petition under the circumstances of this case. The first reason is that there is no provision in the Family Court Act or in the Social Services Law that permits a private citizen, or an agency for that matter, from bypassing an article 10 neglect or abuse finding and proceeding directly to a TPR proceeding. Admittedly, it can be done quickly. In this case, the agency could have filed an abuse petition against the father and asked for a no reasonable efforts finding. The Department would have been granted summary judgment on the severe abuse fact issue because the criminal conviction was based on proof beyond a reasonable doubt which is higher than the clear and convincing evidence standard required to support a termination of parental rights (see Social Services Law § 384-b [3] [g]). If the court also made a “no reasonable efforts” finding, the Department could then proceed directly on a petition to terminate the father’s rights under Social Services Law § 384-b (see Social Services Law § 384-b [8] [d]).

What is clear from a fair reading of Family Court Act article 10 and Social Services Law § 384-b, is that it is the agency that must be involved in the reasonable efforts and diligent efforts mandates of those statutes.

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Related

In re the Guardianship & Custody of Paul C.
28 Misc. 3d 1012 (NYC Family Court, 2010)

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Bluebook (online)
21 Misc. 3d 864, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-guardianship-custody-of-paul-c-nycfamct-2008.