Mitchell v. Thayer

CourtSupreme Court of Delaware
DecidedJanuary 29, 2024
Docket174, 2023
StatusPublished

This text of Mitchell v. Thayer (Mitchell v. Thayer) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mitchell v. Thayer, (Del. 2024).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JACK MITCHELL, § § C.A. No. 174, 2023 Respondent Below, § Appellant, § Court Below—Family Court § of the State of Delaware v. § § File No. 22-10-04TN RACHEL and JOSHUA § Petition No. 22-21367 THAYER, § § Petitioners Below, § Appellees. §

Submitted: January 10, 2024 Decided: January 29, 2024

Before SEITZ, Chief Justice; VALIHURA, TRAYNOR, LEGROW, and GRIFFITHS, Justices, constituting the Court en Banc.

Upon appeal from the Family Court of the State of Delaware. REVERSED AND REMANDED.

Regina S.E. Murphy, Esquire and Amy E. Tryon, Esquire, Barnes & Thornburg LLP, Wilmington, Delaware, for Appellant Jack Mitchell.

Dana L. Reynolds, Esquire, Law Offices of Dana Reynolds, LLC, Wilmington, Delaware, for Appellees Rachel and Joshua Thayer.

GRIFFITHS, Justice: Our nation’s highest court has recognized that natural parents have a

fundamental liberty interest in the custody of their children.1 There are fewer bonds

more profound than the one that binds parents and their children. When a court

considers whether to sever such a bond through the termination of parental rights,

the burden of proof is clear and convincing evidence that the statutory grounds for

termination are met.

This case, as the Family Court acknowledged, is a difficult and unusual one.

Exactly six months after the guardians assumed custody of the minor child, they filed

for termination of the natural father’s parental rights for one of his children. The

Family Court granted the petition. It found that the child’s guardians had proven by

clear and convincing evidence that the natural father had intentionally abandoned

the child for a consecutive six-month period in the twelve months preceding the

petition and that the “best interests” factors favored termination of his parental

rights.

This is a challenging case that will inevitably cause unhappiness and

emotional upheaval for some of the participants. The guardians undoubtedly love

the minor child and have cared for him for most of his young life. But there is not

1 Santosky v. Kramer, 455 U.S. 745, 753 (1982); see also Troxel v. Granville, 530 U.S. 57, 65 (2000) (“The liberty interest at issue in this case—the interest of parents in the care, custody, and control of their children—is perhaps the oldest of the fundamental liberty interests recognized by this Court.”). 2 clear and convincing evidence in the record to support the Family Court’s holding

that the father intentionally abandoned the child, and we therefore REVERSE the

trial court’s judgment.

I. FACTUAL AND PROCEDURAL BACKGROUND2

Jack Mitchell is the biological father of J.M., born on November 21, 2021.3

J.M.’s biological mother, V.H.,4 passed away unexpectedly a few weeks after giving

birth to him.5 Mitchell and V.H. also have two older children, M.M. and L.M., both

of whom remain in Mitchell’s custody.6

When J.M. was born, Mitchell reached out to a caregiver, Bianca Franco, for

childcare assistance with M.M. and L.M.7 In the months following V.H.’s passing,

several people helped Mitchell care for the three children, including his father, his

father’s girlfriend, and Franco and her husband.8 In December 2021, Franco

contacted co-workers at the hospital where she worked as a nurse to see if anyone

2 The facts, except as otherwise noted, are taken from the transcript of hearing testimony. See Am. App. to Opening Br. at A55–529 (Hearing Transcript [hereinafter “Hrg. Tr. at [_]”]). 3 The Court assigned pseudonyms on appeal pursuant to Del. Supr. Ct. R. 7(d). 4 V.H. also has three other children who are not related to Mitchell. Am. App. to Opening Br. at A393 (Jack Mitchell Testimony [hereinafter “Mitchell Test. at [_]”] at 89:7–8). The three other children are in the custody of their biological father. Id. at A432 (Mitchell Test. at 128:1–16). 5 Am. App. to Opening Br. at A19; id. at A400 (Mitchell Test. at 96:1–6). 6 Id. at A393, A395 (Mitchell Test. at 89:1–6, 91:5–6). 7 Id. at A20; A33; A343–44 (Bianca Franco Testimony [hereinafter “Franco Test. at [_]”] at 39:11– 40:6); id. at A399 (Mitchell Test. at 95:14–18); Opening Br. Ex. A (“TPR Order”) at 2. 8 Am. App. to Opening Br. at A353 (Franco Test. at 49:18–21); id. at A404–05 (Mitchell Test. at 100:5–101:6). 3 could assist in caring for Mitchell’s children.9 A co-worker recommended that she

contact Rachel Thayer, a fellow nurse at the same hospital.10 Rachel Thayer and her

husband, Joshua Thayer, agreed to provide childcare to J.M.11

The Thayers first met J.M. on March 23, 2022, when Franco brought him to

their house for a visit.12 After that visit, the Thayers and Franco began taking turns

caring for J.M.13 On April 1, 2022, Mitchell and the Thayers met for the first time.14

At the time, Mitchell was struggling with V.H.’s death and was living in a motel

with his two other children.15 Franco and the Thayers continued to share childcare

responsibilities until April 6, 2022, when Mitchell was arrested on an outstanding

Maryland warrant.16 The following day, Mitchell, Franco, the Thayers, and Marcia

Glover, a social worker for the Division of Services for Children, Youth, and their

Families (“DSCYF”) who was assigned to the matter, held a safety plan meeting to

ensure that the children would be cared for in his absence.17

9 Id. at A352 (Franco Test. at 48:5–16); TPR Order at 2. 10 Am. App. to Opening Br. at A352 (Franco Test. at 48:8–13); TPR Order at 2. 11 Am. App. to Opening Br. at A353 (Franco Test. at 49:12–17); id. at A179 (Rachel Thayer Testimony [hereinafter “R. Thayer Test. at [_]”] at 125:4–14); TPR Order at 2. 12 Am. App. to Opening Br. at A179 (R. Thayer Test. at 125:18–22); TPR Order at 2. 13 Am. App. to Opening Br. at A354–55 (Franco Test. at 50:5–51:24); id. at A182–83 (R. Thayer Test. at 128:8–13, 129:3–9); TPR Order at 2. 14 Am. App. to Opening Br. at A184 (R. Thayer Test. at 130:5–8); TPR Order at 10. 15 Am. App. to Opening Br. at A402 (Mitchell Test. at 98:1–7); id. at A99 (Marcia Glover Testimony [hereinafter “Glover Test. at [_]”] at 45:5–9); TPR Order at 2, 9. 16 Am. App. to Opening Br. at A355 (Franco Test. at 51:22–24); id. at A189 (R. Thayer Test. at 135:3–16); TPR Order at 2. Mitchell was released later that day. See Opening Br. at 2 n.4. 17 Am. App. to Opening Br. at A94–98 (Glover Test. at 40:9–41:2, 42:13–44:6); TPR Order at 2. Glover testified that she is considered an “investigator” and that “any time a report comes through 4 At the April 7, 2022 meeting, Mitchell indicated that he would agree to the

Thayer’s appointment as J.M.’s guardians.18 On April 12, 2022, Mitchell officially

consented to the Thayers serving as guardians of J.M.19 Mitchell was not present at

J.M.’s guardianship hearing in May 2022 because he was incarcerated in Maryland

for a period of two and a half weeks.20 Due to Mitchell’s brief incarceration, DSCYF

took custody of M.M. and L.M. temporarily, but promptly returned custody to

Mitchell when he was released from prison.21 On May 25, 2022, the Family Court

awarded guardianship of J.M. to the Thayers.22

By the end of summer 2022, Mitchell had moved into a house with M.M. and

L.M. and had started his own business.23 On September 30, 2022, Shannon Ruello,

a family crisis therapist for DSCYF, was assigned to J.M.’s case.24 At that point,

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