In the interest of Phillips

806 A.2d 616, 2002 WL 31094507
CourtDelaware Family Court
DecidedJuly 1, 2002
DocketNo. CS01-04269; Petition No. 01-25453
StatusPublished
Cited by3 cases

This text of 806 A.2d 616 (In the interest of Phillips) is published on Counsel Stack Legal Research, covering Delaware Family Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the interest of Phillips, 806 A.2d 616, 2002 WL 31094507 (Del. Super. Ct. 2002).

Opinion

MILLMAN, J.

In this case, the Court is called upon to determine if title 11, section 1103(d) of the Delaware Code violates the separation of powers doctrine by unjustifiably permitting the Department of Services for Children, Youth and Their Families (“the Department”) to be the sole arbiter regarding whether reunification services are to be provided to a parent after this Court determines the parent has committed an act under title 13, section 1103(a)(4) of the Delaware Code.

After reviewing the separation of powers doctrine and the legislative history of title 11, section 1103(d), I find that section 1103(d) does not violate the doctrine. Accordingly, in those cases where this Court determines a parent to have violated title 13, section 1103(a)(4) of the Delaware Code, the Department shall be the sole arbiter as to whether reunification services are to be provided.

[617]*617Facts

On August 14, 2001, custody of Ann Margaret Phillips was granted to the Department of Services for Children, Youth and Their Families (“the Department” or “DFS”). The child’s parents are Kristin A. Phillips (“mother”) and Mark T. Harper (“father”).2

DFS moved this Court for a finding that mother had committed an offense set forth in title 13, section 1103(a)(4) of the Delaware Code3 shortly after Ann came into the custody of DFS. Such a finding would form a ground for DFS to bring a termination of parental rights action against mother. On October 30, 2001, this Court found that the Superior Court of the State of Delaware had convicted mother of the manslaughter of Ann’s sibling on February 14, 1996. Pursuant to title 13, section 1103(a)(4)(a) of the Delaware Code, mother’s conviction is a ground for DFS to move to terminate mother’s parental rights. DFS now contends that because a ground to terminate mother’s parental rights has been established under section 1103(a)(4)(a), DFS becomes the sole arbiter regarding whether or not reunification services are to be offered to mother. DFS further contends that if this Court requires it to offer services to the offending parent, in contravention to section 1103(a)(5)(d), this Court will violate the separation of powers doctrine.

Mother argues that there is no statutory prohibition against offering her reunification services, even after this Court found she committed an act which forms a basis to terminate her parental rights under section 1103(a)(4)(a). Mother also argues that it is this Court, and not the Department, which is charged with the responsibility of determining if reunification services were properly withheld from a parent.

Lastly, mother argues that to permit the Department to unilaterally decide whether or not a parent is to receive services would be an infringement upon the authority of the judicial branch of government.

Reasonable Efforts

With the enactment by Congress of the Adoption Assistance and Child Welfare Act of 1980 (“the Child Welfare Act”), this Court became charged with the duty of “insuring] meaningful compliance with the Child Welfare Act of 19804.. .and the appropriate Delaware Law....”5 Included in this duty of insuring compliance with the applicable federal and state law, is the Court’s obligation to determine if the Department, in a given case, is required to exercise reasonable efforts. Where the Department is obligated to provide reunification services, the Court is required to determine whether these services are rea[618]*618sonable in the particular case.6

In addition to federal law, Delaware has its own statutory authority requiring reunification services to dependent children and their families.7 This Court’s responsibility, and obligation, to determine if the reasonable efforts requirement has been met under both federal and state law is well settled. As our Supreme Court has stated, “Under Delaware Law, termination of parental rights can only occur if the Family Court is satisfied DFS exerted all reasonable efforts...to reunify [children] with their natural parent.”8

In 1997, Congress amended the Child Welfare Act. One amendment to that act eliminated the need for states to provide reunification services to a parent if that parent was found to have subjected a child to “aggravating circumstances.” These aggravating circumstances were defined to be specific enumerated acts committed against the child or that child’s sibling who is the subject of the case before the Court.9

Shortly after the passage of 42 U.S.C. § 671(a)(15)(D), Delaware amended its termination of parental rights statute to include grounds which reflect the federal Act.10 It is not disputed that mother has been found to have violated section 1103(a)(4)(a) by committing the manslaughter of Anris sibling. At the time section 1103(a)(4) was adopted, our General Assembly also enacted § 1103(a)(5)(d) which states:

(d) The Department is not required to perform, but is not prohibited from performing, reunification and related services as outlined in Chapter 90 of Title 29 when the grounds for termination of parental rights are those stated in subsections (a)(2), (4) or (6) of this section.

The Department contends the language of section 1103(d) eliminates the requirement that reunification services be offered to a parent in cases where this Court finds the parent committed an act under section 1103(a)(4).

[619]*619The 1997 Amendment to the Child Welfare Act no longer required states to provide reunification services to receive federal funding in cases where aggravating circumstances exist. As mother contends, under this amendment, states are not prohibited from offering services in cases where aggravating circumstances exist.11 Our General Assembly, in contrast to the blanket exception contained in the federal act, adopted a more moderate policy. The policy recognizes there may be cases where, despite a finding of an aggravated circumstance, facts may exist that justify the offering of services by the Department to a parent and child. The offering of these services may then lead to the safe reunification of that family.

Separation of Powers

It is undisputed.. .that the doctrine of separation of powers is integral to the fabric of the Delaware Constitution. ... However, the Supreme Court has recognized that ‘strict adherence and complete separation of governmental departments is neither desirable nor intended.... [Instead, a] certain degree of flexibility in the application of the Doctrine is essential to the maximum success of our constitutional system. .. ,’12

In Opinion of the Justices,13 our Supreme Court set forth a test to be applied in those cases where it is alleged a particular legislative enactment violates the separation of powers doctrine. The Court said,

First is the essential nature of the power being exercised. Is the power exclusively executive or [judicial] or is it a blend of the two? A second factor is the degree of control by the [executive] department in the exercise of the power.

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Cite This Page — Counsel Stack

Bluebook (online)
806 A.2d 616, 2002 WL 31094507, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-phillips-delfamct-2002.