In Re Thomas Minors

CourtMichigan Court of Appeals
DecidedJanuary 4, 2024
Docket364249
StatusUnpublished

This text of In Re Thomas Minors (In Re Thomas Minors) 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 Thomas Minors, (Mich. Ct. App. 2024).

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UNPUBLISHED In re THOMAS, Minors. January 4, 2024

No. 364249 Oakland Circuit Court Family Division LC No. 2009-757748-NA

Before: GLEICHER, C.J., and GARRETT and MALDONADO, JJ.

PER CURIAM.

In this child protective proceeding, the minor children, EET and MDT, by their Next Friend, E. Smith, appeal as of right the trial court’s order declining to exercise jurisdiction over them and dismissing the petition to terminate the parental rights of respondents, their mother and father. We remand for appropriate findings of fact and articulation of a jurisdictional analysis that is amenable to appellate review.

I. BACKGROUND

In November 2019, the Department of Health and Human Services (“the Department”) petitioned to terminate respondents’ parental rights to EET and MDT. The petition raised allegations of physical, educational, and medical neglect, improper supervision, and physical and sexual abuse. After several adjournments of the preliminary hearing to comply with the Indian Child Welfare Act, 25 USC 1901 et seq., and the Michigan Indian Family Preservation Act, MCL 712B.1 et seq., the trial court authorized the petition in February 2021. An adjudicative bench trial took more than seven months and concluded in February 2022. The trial court heard testimony from, among others, respondent-mother, respondent-father, the assigned CPS investigator, and MDT’s teacher. Unfortunately, because of personal family matters, the trial court did not issue a decision until September 1, 2022. On that date, the court read into the record its opinion declining to take jurisdiction over the children. The court entered an order dismissing the petition, finding that the Department failed to establish by a preponderance of the evidence statutory grounds to exercise jurisdiction over the children.

-1- This appeal on behalf of EET and MDT followed.1

II. ANALYSIS

Next Friend E. Smith argues that the trial court erred when it declined to exercise jurisdiction over the minor children.2

“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). The adjudicative phase determines whether the trial court can exercise jurisdiction over the children. Id. This process begins “when a petition is filed in the trial court that contains facts constituting an offense against a child under MCL 712A.2(b) of the juvenile code, MCL 712A.1 et seq.” In re Long, 326 Mich App 455, 459; 927 NW2d 724 (2018). After a petition has been filed, “the trial court must hold a preliminary hearing and may authorize the filing of the petition upon a finding of probable cause that one or more of the allegations [in the petition] are true and could support the trial court’s exercise of jurisdiction under MCL 712A.2(b).” In re Ferranti, 504 Mich 1, 15; 934 NW2d 610 (2019). If the court authorizes the petition, the respondent-parent can demand a trial to contest its merits. Sanders, 495 Mich at 405. Following a trial, the court may exercise jurisdiction if the Department proves “by a preponderance of the evidence one of more of the statutory grounds for jurisdiction alleged in the petition.” Id.

Smith argues that a preponderance of the evidence supports the assumption of jurisdiction over EET and MDT. We conclude, however, that the trial court erred by failing to make adequate findings of fact and conclusions of law to properly articulate why the children did not come within its jurisdiction.

1 After the trial court dismissed the petition, the then-appointed LGAL filed a claim of appeal on behalf of EET but mistakenly chose not to include MDT. The Department and the newly retained LGAL sought to correct this error by moving to reinstate MDT to the appeal. We granted this motion. In re E.E. Thomas Minor, unpublished order of the Court of Appeals, entered November 28, 2023 (Docket No. 364249). 2 Respondents argue that this Court lacks jurisdiction over this appeal because the claim of appeal was not timely filed. Respondent-mother previously made this argument in a motion to dismiss, which this Court denied. In re E. E. Thomas Minor, unpublished order of the Court of Appeals, entered May 24, 2023 (Docket No. 364249). “Whether this Court has jurisdiction to hear an appeal is always within the scope of this Court’s review,” Chen v Wayne State Univ, 284 Mich App 172, 191; 771 NW2d 820 (2009), so we are not bound by this Court’s unpublished order denying respondent-mother’s motion to dismiss. That said, upon reexamination of the jurisdictional question, we conclude that our jurisdiction over this appeal is proper. Smith timely requested appointment of appellate counsel on December 12, 2022, after the trial court’s order denying reconsideration. See MCR 3.993(D)(1). On December 16, 2022, the trial court entered an order appointing counsel, and the claim of appeal was timely filed within 21 days of that order under MCR 7.204(A)(1)(b).

-2- We review a trial court’s decision to exercise jurisdiction over a child for clear error in light of the court’s findings of fact. In re Kellogg, 331 Mich App 249, 253; 952 NW2d 544 (2020). Clear-error review considers whether “the reviewing court has a definite and firm conviction that a mistake has been committed, giving due regard to the trial court’s special opportunity to observe the witnesses.” Id. (cleaned up). Explicit in this Court’s standard of review is the expectation that the trial court will review and weigh the evidence, and then make findings of fact. “The trial court’s findings need not be extensive; ‘brief, definite, and pertinent findings and conclusions on contested matters are sufficient.’ ” In re MJC, ___ Mich App ___, ___; ___ NW2d ___ (Docket No. 365616); slip op at 10, quoting MCR 3.977(I)(1). But in this case, the trial court did not satisfy these minimal requirements.

The adjudicative trial was held over eight days between July 2021 and February 2022. After the parties presented their closing arguments, the trial court took the matter under advisement. In September 2022, the court held a hearing to announce its decision on the record. At the outset, the court identified the witnesses and the relevant jurisdictional statutes. The court then noted that several of the allegations in the petition were undisputed—those related to respondents’ prior CPS history and the prior termination of respondent-mother’s parental rights to six other children. The remaining allegations in the petition were considered disputed. The court then read each allegation into the record and summarized, in great detail, trial testimony that was arguably related to the allegation. The court, however, did not engage in any analysis of the evidence, announce any credibility determinations, or otherwise make any findings of fact about the disputed matters.3 The court simply summarized the testimony of each witness. When it was done with this exercise, the court abruptly concluded, without any analysis, that the Department failed to establish by a preponderance of the evidence that the children came within the court’s jurisdiction. Although the court reached a decision on jurisdiction, it did not make adequate findings of fact to permit meaningful appellate review of its decision. That is, the trial court did not explain how it resolved the many disputed issues to enable this Court to understand why it determined that the evidentiary record did not warrant the assumption of jurisdiction.

The nature of the court’s analysis renders the record inadequate for appellate review.

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Related

Chen v. Wayne State University
771 N.W.2d 820 (Michigan Court of Appeals, 2009)
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)

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Bluebook (online)
In Re Thomas Minors, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-thomas-minors-michctapp-2024.