In re the Guardianship of Doe

101 P.3d 684, 106 Haw. 75, 2004 Haw. App. LEXIS 388
CourtHawaii Intermediate Court of Appeals
DecidedNovember 9, 2004
DocketNo. 25973
StatusPublished
Cited by5 cases

This text of 101 P.3d 684 (In re the Guardianship of Doe) is published on Counsel Stack Legal Research, covering Hawaii Intermediate 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 the Guardianship of Doe, 101 P.3d 684, 106 Haw. 75, 2004 Haw. App. LEXIS 388 (hawapp 2004).

Opinion

Opinion of the Court by

LIM, J.

Maternal grandmother and grandfather (collectively, the Grandparents) appeal the July 9, 2003 order of the family court of the first circuit,1 made upon findings of fact and conclusions of law entered on June 17, 2003, that denied their January 9, 2003 petition for co-guardianship of the person of their then four-year-old grandson.2 The Grandparents [77]*77also appeal the family court’s July 9, 2008 order that denied their June 17, 2003 motion for reconsideration.

The Grandparents first contend the family court erred in deciding whether the natural father3 was an unfit parent, In re Guardianship of John Doe, 7 Haw.App. 575, 581, 786 P.2d 519, 523 (1990) (“in a contest between the mother and the paternal grand mother for a child’s custody, the mother must prevail absent a valid finding that she is not a fit and proper person or has a home that is not stable and wholesome”); In re Guardianship of Jane Doe, 93 Hawai'i 374, 381, 4 P.3d 508, 515 (App.2000) (quoting In re Guardianship of John Doe, supra), because the family court applied the clear and convincing evidence standard of proof4 to that question. We agree.

The heightened standard of proof is applied in termination of parental rights cases under Hawaii Revised Statutes (HRS) § 571-61 et seq. (1998) because,

The very act of severing the parent-child relationship is cognizably absolute and irrevocable.... [Standards of proof function to indicate the relative importance attached to the ultimate decision and to allocate the risk of error between litigants accordingly.... Termination is a drastic remedy and is of such weight and gravity that due process requires the state to justify termination of the parent-child relationship by proof more substantial than a preponderance of the evidence.

Woodruff v. Keale, 64 Haw. 85, 100-101, 637 P.2d 760, 770 (1981) (citations, internal quotation marks and block quote format omitted). See also HRS § 587-73(a) (Supp.2003) (requiring “clear and convincing evidence” before the family court may terminate parental rights in a child protective act permanent plan hearing); In re Jane Doe, 95 Hawai'i 183, 192, 20 P.3d 616, 625 (2001) (“the [child protective act, HRS ch. 587 (1993 & Supp. 2003),] does not allow for the divestiture of parental rights absent clear and convincing evidence” (emphasis in the original)).

While a termination of parental rights is “absolute and irrevoeable[,]” Woodruff, 64 Haw. at 100, 637 P.2d at 770; see also In re Jane Doe, 95 Hawai'i at 192-193, 20 P.3d at 625-26; HRS § 587-2 (1993) (definition of “permanent custody”), “a guardian may be appointed for a minor even where the parental rights of the minor’s parents have not been terminated.” In re Guardianship of Jane Doe, 93 Hawai'i at 383, 4 P.3d at 517.

We have held that,

Because [the] concepts [of custody and guardianship] share common attributes, we construe the custody guardianship provision of HRS § 560:5-209 [ (1993) ] and the custody provision in HRS § 571-46 [ (Supp.2003) ] in pan materia5 in order to [78]*78determine the appropriate standard to be applied where conflicting claims between parents and non-parents are made in a guardianship hearing. See HRS § 1-16 (1993) (“Laws in pari materia, or upon the same subject matter, shall be construed with reference to each other.”).

Id. (footnote supplied).' Accordingly, we observe that a guardianship of the person of a minor, while it bestows “the powers and responsibilities of a parent who has not been deprived of custody of the parent’s minor and unemancipated child,” HRS § 560:5-209; see also In re Guardianship of Jane Doe, 93 Hawai'i at 382, 4 P.3d at 516 (“guardians of a minor have the powers and responsibilities otherwise inherent in parenthood”); HRS § 571-2 (1993) (definition of “legal custody”), nevertheless remains “subject to residual parental rights and responsibilities!;,]” id., meaning “those rights and responsibilities remaining with the parent after the transfer of legal custody or guardianship of the person, including, but not necessarily limited to, the right to reasonable visitation, consent to adoption or marriage, and the responsibility for support.” Id. (definition of “residual parental rights and responsibilities”); cf. HRS § 571-46(7) (Supp.2003) (unless detrimental to the best interests of the child, reasonable visitation rights “shall be awarded to parents, grandparents, siblings, and any person interested in the welfare of the child in the discretion of the court”). Furthermore, a guardian of the person of a minor always remains subject to removal, as such. HRS § 560:5— 212 (1993); cf. HRS § 571-46(6) (Supp.2003) (a custody award “shall be subject to modification or change whenever the best interests of the child require or justify the modification or change”).

Hence, a guardianship of the person of a minor is neither absolute nor irrevocable, and the heightened standard of proof attendant upon those attributes of a termination of parental rights need not attend here.6 We conclude the family court erred in applying a heightened standard of proof to the question of the fitness of the natural father.

The family court found that the Grandparents “have provided the minor child, their grandson, with a home, food[,] shelter, education and affection, together with the minor child’s siblings. The Court finds on the basis of the evidence submitted and the lack of any contrary evidence, that they are fit and competent persons to serve as Guardians of the minor child.” See HRS § 560:5-204 (1993) (“The family court may appoint any competent person whose appointment would be in the best interest of the minor as a guardian of the person for an unmarried minor.”); HRS §

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Bluebook (online)
101 P.3d 684, 106 Haw. 75, 2004 Haw. App. LEXIS 388, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-guardianship-of-doe-hawapp-2004.