LDM v. RA

37 Misc. 3d 767
CourtNew York Supreme Court
DecidedSeptember 5, 2012
StatusPublished

This text of 37 Misc. 3d 767 (LDM v. RA) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LDM v. RA, 37 Misc. 3d 767 (N.Y. Super. Ct. 2012).

Opinion

OPINION OF THE COURT

Diane Kiesel, J.

The parties are the parents of a nine-year-old boy, D. The petitioner mother is seeking to modify a prior weekend visitation order to require that all contact between D. and his father take place at a social work agency in the presence of a supervisor. She claims in a modification petition filed May 1, 2012 that the respondent father has been driving in a fast and reckless manner with D. in the car and has further endangered the boy [769]*769by shoplifting with him at Macy’s department store. The respondent father denies the allegations.

The attorneys for the mother and child are seeking to have the court admit into evidence the child’s out-of-court statements regarding the father’s alleged behavior. They are also seeking to corroborate those statements with the child’s in camera testimony. At the direction of the court, counsel for all the parties submitted briefs on the issue. For the reasons set out below, the application to admit the child’s out-of-court statements is granted but they must be corroborated by evidence other than the child’s in camera statements. Such corroborating evidence may be the child’s testimony as a trial witness in the courtroom, where he will be subject to cross-examination. In such an instance, the parents, who are represented by counsel, will be excluded from the courtroom.

Factual Background

At a hearing on June 8, 2012, at which the mother attempted to prove her allegations, she was asked during direct examination to testify as to what D. told her about these incidents. The father’s counsel objected, arguing D.’s statements constituted inadmissible hearsay. Counsel for both the mother and the child argued they were admissible pursuant to case law allowing the admission of statements by children that relate to abuse or neglect. A lengthy discussion ensued and the parties were asked to brief the issue.

The Law — Hearsay Statements Regarding Abuse and Neglect

Family Court Act § 1046 (a) (vi), which governs formal neglect proceedings, provides an exception to the rule against hearsay and allows into evidence prior statements made by children regarding allegations of abuse or neglect. To sustain a neglect finding, however, the statements must be corroborated. “ [Previous statements made by the child relating to any allegations of abuse or neglect shall be admissible in evidence, but if uncorroborated, such statements shall not be sufficient to make a fact-finding of abuse or neglect.” (Id.) The corroboration may include “[a]ny other evidence tending to support the reliability of the previous statements.” (Id.) There are no similar provisions in Family Court Act, article 6, § 651 or Domestic Relations Law § 240, which govern child custody determinations.

Courts around the state have determined, usually without articulating any rationale, that a child’s out-of-court statements about abuse or neglect are admissible in custody and visitation proceedings just as they are in formal neglect cases. See Matter [770]*770of Mildred S.G. v Mark G. (62 AD3d 460, 462 [1st Dept 2009]), in which the Court determined in a custody matter, without explanation, that the law allowing an exception to the rule against hearsay for a child’s prior statements of abuse and neglect in article 10 proceedings “is applicable here.” In so ruling, it cited to the Second Department case of Matter of Albert G. v Denise B. (181 AD2d 732 [1992]), where the Court accepted hearsay testimony from witnesses who said an eight-year-old boy told them his mother used cocaine in his presence and tried to get him to use it. Again, without analysis or discussion, the Court determined “since the witnesses’ testimony concerned allegations of abuse, the hearsay exception provided for in Family Court Act § 1046 can be applied.” (181 AD2d at 733.) Similarly, in Matter of Kimberly CC. v Gerry CC. (86 AD3d 728, 730 [2011]), the Third Department held a child’s out-of-court statements regarding sexual abuse by her father to be admissible in a custody proceeding, citing to Family Court Act § 1046 (a) (vi) for support. Likewise, in the Fourth Department, the admission of a child’s hearsay statement about abuse in a custody matter has been upheld. (See Matter of Sutton v Sutton, 74 AD3d 1838 [2010]; see also Matter of Mateo v Tuttle, 26 AD3d 731 [4th Dept 2006].)

Clearly, the tacit expansion by the New York appellate courts of the article 10 hearsay exception to article 6 custody matters makes sense. Courts have a duty in all matters involving custody to act in “the best interests of the child.” (Domestic Relations Law § 240 [1] [a]; Eschbach v Eschbach, 56 NY2d 167 [1982].) The most serious abuse or neglect of children naturally takes place out of the public eye. The legislature recognized the only way to protect children is to allow their out-of-court statements into evidence. Although the legislature has not addressed the issue outside the neglect context, the courts recognize that children’s statements about abuse or neglect are equally valuable in custody proceedings. The family courts cannot be put in the untenable position of inadvertently granting custody or visitation rights to an abusive parent. In that the duty of the court in making custody determinations is to act in a child’s best interest, that duty is best met by considering all the evidence available to protect that child. Accordingly, it is appropriate to admit the prior out-of-court statements of a child regarding abuse or neglect through the testimony of a person in whom the child has confided. In this case, D. made statements about his father’s behavior — which the petitioner maintains go to abuse or neglect — to his mother.

[771]*771The Law — What Constitutes Abuse or Neglect

The statements counsel for the mother and the child seek to introduce through the mother revolve around two incidents: one, where the father allegedly shoplifted from a department store while with D., resulting in their arrest, and the other, where the father drove at such an excessive rate of speed he caused D. to become ill and vomit. With regard to the shoplifting allegations, in a case directly on point, Matter of Bernthon v Mattioli (34 AD3d 1165, 1166 [3d Dept 2006]), the Court upheld the admission of a child’s out-of-court statements regarding his mother’s use of him as a decoy while she shoplifted as “they would support a finding of neglect.”

Similarly, another Court determined a father was neglectful where he drove a car with his daughter after drinking alcohol and failed to place her in a child seat or restraint and allowed his son to ride in a car with a friend he knew or should have known was intoxicated. (Matter of Bianca P. [Theodore A.P.], 94 AD3d 1126, 1126-1127 [2d Dept 2012].) Whether harm actually befalls a child is irrelevant, what matters is whether the parent has placed the child in “risk of substantial harm,” even if no injury is suffered. (Matter of Pedro C. [Josephine B.], 1 AD3d 267, 268 [1st Dept 2003].)

Here, the mother seeks to introduce D.’s statements to her involving his father’s shoplifting in his presence and his father’s reckless driving while D. was in the car. Both these statements, under the principles stated in the Bernthon and Bianca cases, go to possible abuse or neglect and are, therefore, admissible here.

The Law — Corroboration Requirements

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In re Christina F.
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In re Pedro C.
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Mateo v. Tuttle
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Mildred S.G. v. Mark G.
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In re Martha Z.
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Sandra S. v. Abdul S.
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Bluebook (online)
37 Misc. 3d 767, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ldm-v-ra-nysupct-2012.