Matter of Welfare of Mullins

298 N.W.2d 56, 1980 Minn. LEXIS 1583
CourtSupreme Court of Minnesota
DecidedSeptember 12, 1980
Docket50185
StatusPublished
Cited by33 cases

This text of 298 N.W.2d 56 (Matter of Welfare of Mullins) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Welfare of Mullins, 298 N.W.2d 56, 1980 Minn. LEXIS 1583 (Mich. 1980).

Opinions

SHERAN, Chief Justice.

This appeal arises from a petition for a finding of dependency or neglect filed in the Hennepin County District Court by appellants Earl and Anne Krolick on behalf of their foster child, Carl Otis Mullins, against that child’s natural father, respondent Carl E. Mullins. Appellants’ action was precipitated by an August 25, 1978, order of the Superior Court of San Diego, California authorizing the removal of their foster child from Minnesota and his placement in the home of his great aunt in San Diego. A temporary restraining order enjoining the child’s removal issued from the Hennepin County District Court on September 1,1978, and a temporary injunction was granted on [58]*58September 5, 1978. On May 1, 1979, the district court dissolved the injunction and dismissed the petition, concluding that California retained jurisdiction. No trial on the merits has been had on the substantive merits of appellants’ petition in neglect and dependency. Their appeal to this court is therefore limited solely to the question of jurisdiction. We affirm the judgment of the district court.

On July 29, 1975, the Superior Court of San Diego, California, finding that the conviction and incarceration of respondent for the murder of his wife rendered their five year-old child Carl Mullins without a parent or guardian available to exercise proper parental control, adjudged Carl Mullins dependent within the meaning of § 600(a) of the California Welfare and Institutions Code and placed him under the supervision of the Director of the San Diego County Department of Public Welfare. For current enactment, see Cal.Welf. & Inst.Code § 300(a) (West Cum.Supp.1980).1 Following a study by the San Diego County Department of Public Welfare, the Superior Court determined that the best interests of the child would be served by his placement in the home of his maternal aunt and uncle in Minneapolis. See Cal.Welf. & Inst.Code § 726(c) (West Cum.Supp.1980).2 Accordingly, the child arrived in Minnesota in early September of 1975. In ordering the child’s placement in Minnesota, however, the Superior Court expressly reserved jurisdiction, see § 607 of the California Welfare and Institutions Code now codified at Cal. Welf. & Inst.Code § 301 (West Cum.Supp. 1980),3 decreeing that annual dependency review hearings be held in California. The court further arranged that the Hennepin County Welfare Department would supervise the child on its behalf and file quarterly assessments with the San Diego County Department of Public Welfare. The assessments were in fact conducted and the reports forwarded as requested. Likewise, hearings to review the child’s placement were held in California in the late summers of 1976, 1977 and 1978. Following each hearing, the court issued an order continuing the status of Carl Mullins as a dependent child. By 1978, Carl’s father had been paroled and reintegrated into the San Diego community, and in the judgment of the San Diego Welfare Department, was capable of providing for his now eight year old son. To facilitate the ultimate rapprochement of parent and child, the Superior Court at the 1978 dependency hearing ordered Carl’s removal from Minnesota and his placement in the home of a paternal great aunt in San Diego. Apprized of this disposition, Carl’s foster parents, the Krolicks, filed a petition in the Hennepin County District Court for an order enjoining his removal and for a finding of neglect or dependency under Chapter 260 of the Minnesota statutes. The procedural meanderings described above and this appeal followed thereafter.

The disposition of this case depends on the construction we afford to the Uniform Child Custody Jurisdiction Act [UCCJA], applicable provisions of which we adopted [59]*59by judicial fiat in In re Petition of Giblin, 304 Minn. 510, 232 N.W.2d 214 (1975) and which the legislature enacted in toto in 1977. See Minn.Stat. § 518A.01-.25 (1978 & Supp.1979). The UCCJA, promulgated by the American Bar Association in 1968 and thus far adopted by the legislatures of 35 states, attempts to minimize the hardships visited upon children through divorce or other forced separations by reducing the opportunities for inter jurisdictional controversies over child custody. See generally Uniform Child Custody Jurisdiction Act § 1; Minn.Stat. § 518A.01 (1978).

Appellants, in bringing their action in the Hennepin County District Court, sought a determination that Minnesota, to the exclusion of California, was the “home state” of their foster child,4 or alternatively, that the child has such “significant connections” with Minnesota as to afford this state primary jurisdiction.5 This interpretation would render California without jurisdiction to enforce its dependency decree ordering the removal of the child.

The district court, agreeing that the UCCJA governed the disposition of the case, concluded that because the Superior Court placed the child out of state pursuant to a finding of dependency and maintained its interest through quarterly assessments and annual hearings, it did not intend the child’s sojourn to be permanent. Although the continuing presence of the child in appellants’ home might suggest a basis for jurisdiction, the strength of the child’s connections with California required a contrary disposition. See Minn.Stat. § 518A.03, subd. 1(b) (1978) quoted in note 5 supra. See also Erickson v. Erickson, 300 Minn. 559, 220 N.W.2d 487 (1974), Fish v. Fish, 280 Minn. 316, 159 N.W.2d 271 (1968) and cases cited therein for the proposition that lower courts dealing with the issue of child custody and control are vested with broad discretion and should not be reversed on appeal unless an abuse is clearly shown.

We agree with the district court that the analytical distinction between custody decrees arising from divorce and those resulting from dependency supports the retention of primary jurisdiction by the State of California and precludes any assertion of primary jurisdiction by the State of Minnesota. Although dependency custody decrees are indeed included within the ambit of the UCCJA, the Act itself is largely intended to address the problems resulting from inter-jurisdictional divorce proceedings. See generally Bodenheimer, The Uniform Child Custody Jurisdiction Act: A Legislative Remedy for Children Caught in the Conflict of Laws, 22 Vand.L.Rev. 1207 (1969). Unlike a dependency order, a typical divorce decree setting forth terms of child custody does not contemplate active supervision by the issuing court. Thus, when the parties to the decree move out of state, their nexus with that court attenuates. Should the need for modification or enforcement of the decree arise, once the child resides in the new locality for six months, the UCCJA permits a transfer of jurisdiction. The issuance of a divorce decree governing custody in one state followed by the move of the custodial parent to another state results in the new place of residence becoming the child’s “home state” for the purposes of the Act. In contrast, a dependency adjudication involves a continuing relationship between the child and the court. The relationship does not attenuate over time but continues as the court periodically assesses [60]

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Bluebook (online)
298 N.W.2d 56, 1980 Minn. LEXIS 1583, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-welfare-of-mullins-minn-1980.