New Jersey Division of Child Protection and Permanency v. J.C. and K.C.

CourtSupreme Court of New Jersey
DecidedMay 29, 2024
DocketA-8-23
StatusPublished

This text of New Jersey Division of Child Protection and Permanency v. J.C. and K.C. (New Jersey Division of Child Protection and Permanency v. J.C. and K.C.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New Jersey Division of Child Protection and Permanency v. J.C. and K.C., (N.J. 2024).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

New Jersey Division of Child Protection and Permanency v. J.C. (A-8-23) (088071)

Argued February 26, 2024 -- Decided May 29, 2024

SOLOMON, J., writing for a unanimous Court.

In this appeal, the Court considers whether a family court judge may dismiss an action for the care and supervision of children brought pursuant to N.J.S.A. 30:4C-12 but continue restraints on a parent’s conduct.

The Division of Child Protection and Permanency (the Division) became involved with J.C. (Jan) and her family in July 2018, when a hospital employee notified the Division that Jan had been involuntarily hospitalized for manic and paranoid behavior. The Division implemented a safety plan that mandated temporary supervision of Jan’s contact with her children. Later, the Division lifted the plan. Following a referral in December 2019, when Jan admitted that she had stopped seeing her therapist and was diagnosed with bipolar disorder with psychotic features, the Division reinstituted the safety plan and filed a complaint. The Family Part granted the Division care and supervision of the children. In March 2021, the Law Guardian sought to dismiss the Title 30 action because of Jan’s lack of cooperation with the Division. The court discontinued the Division’s care and supervision of the children but dismissed the litigation with restraints, deeming it “irresponsible” to allow Jan to have unsupervised contact with the children, considering her mental health issues. The Appellate Division affirmed, and the Court granted certification, 255 N.J. 375 (2023).

HELD: The family court does not have the authority under N.J.S.A. 30:4C-12 to dismiss a Title 30 action -- and with it, a parent’s appointed counsel -- but continue restraints on a parent’s conduct. If the family court finds that it is in the best interests of the child to continue the restraints on a parent’s conduct, it must keep the case open to facilitate judicial oversight of the Division’s continued involvement, while safeguarding a parent’s right to counsel.

1. In DYFS v. I.S., the Court outlined the multi-step process set forth in N.J.S.A. 30:4C-12 which the Division must follow to properly exercise its authority under Title 30. 214 N.J. 8, 34 (2013). First, the Division must investigate following a

1 referral. If, as a result of the investigation, it appears that the child requires care and supervision by the Division or other action to ensure the health and safety of the child, the Division may apply for a court order. The family court must then hold a summary hearing and may issue an order for care and supervision if it is satisfied that the best interests of the child so require. Importantly, N.J.S.A. 30:4C-12 provides that any order entered by the court is effective for six months, after which the Division may apply for an extension. If the court determines that an extension is warranted, care and supervision may be continued thereafter, provided there is periodic review by the family court. The purpose of periodic review is not to check- up on and review a parent’s compliance or to manage the case, but rather to require the Division to demonstrate that continued care and supervision is still in the best interests because there is a need to ensure the child’s health and safety. The Court notes that indigent parents facing either temporary loss of custody or permanent termination of their parental rights have a right to appointed counsel in Title 30 proceedings in light of the magnitude of the consequences involved. (pp. 13-16)

2. Here, the family court’s order terminated the Title 30 matter but maintained restraints upon Jan, which would result in the Division’s continued involvement with the family without the requisite judicial oversight. That is inconsistent with the express provisions of N.J.S.A. 30:4C-12. A case should be dismissed only when the court determines that neither services nor supervision are required to ensure the child’s health and safety. Thus, if the court finds that the Division established by a preponderance of the evidence that restraints on a parent’s contact with her children is in their best interests, the case should not be dismissed. Functionally, when a Title 30 action is terminated, so too is the right to the appointment of counsel. Therefore, if a case is dismissed with continuing restraints, a parent with appointed counsel, like Jan, who seeks review in the future would not be entitled to the assistance of counsel to begin that process, a result that is incompatible with due process and a parent’s right to counsel in Title 30 proceedings. The Court is mindful that Title 30 requires the Division to regularly visit all children under its care and that criteria for determining the frequency and nature of in-person visits by a Division representative are established by regulation. Recognizing that periodic in- person visits to an intact family by a Division representative are inherently disruptive to the family in general and the children in particular, the Court explains that N.J.A.C. 3A:12-2.6 should be amended to provide an exception to regular weekly or monthly visitation where the Division contends, and the family court finds, that the provision of services by the Division is not required. (pp. 17-19)

REVERSED and REMANDED to the Family Part.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, FASCIALE, and NORIEGA join in JUSTICE SOLOMON’s opinion. 2 SUPREME COURT OF NEW JERSEY A-8 September Term 2023 088071

New Jersey Division of Child Protection and Permanency,

Plaintiff-Respondent,

v.

J.C.,

Defendant-Appellant,

and

K.C.,

Defendant.

In the Matter of A.C. and W.C., Minors-Respondents.

On certification to the Superior Court, Appellate Division.

Argued Decided February 26, 2024 May 29, 2024

T. Gary Mitchell, Deputy Public Defender, argued the cause for appellant J.C. (Jennifer Sellitti, Public Defender, Office of Parental Representation, attorney; T. Gary Mitchell, of counsel and on the briefs).

1 Elizabeth H. Wallace, Deputy Attorney General, argued the cause for respondent New Jersey Division of Child Protection and Permanency (Matthew J. Platkin, Attorney General, attorney; Sookie Bae-Park, Assistant Attorney General, of counsel, and Lori J. DeCarlo and Jessica A. Prentice, Deputy Attorneys General, on the briefs).

M. Alexis Pollock, Deputy Public Defender, argued the cause for minors A.C. and W.C. (Jennifer Sellitti, Public Defender, Office of the Law Guardian, attorney; M. Alexis Pollock, of counsel and on the briefs, and Neha Gogate, Assistant Deputy Public Defender, on the briefs).

Molly K.C. Linhorst argued the cause for amicus curiae American Civil Liberties Union of New Jersey (American Civil Liberties Union of New Jersey Foundation, attorneys; Molly K.C. Linhorst, Alexander Shalom, and Jeanne LoCicero, on the brief).

JUSTICE SOLOMON delivered the opinion of the Court.

In this appeal, we are called upon to determine whether a family court

judge may dismiss an action for the care and supervision of children brought

pursuant to N.J.S.A. 30:4C-12 but continue restraints on a parent’s conduct.

The goal of New Jersey’s child welfare system is to better “protect

children from abuse and neglect” by, among other things, providing “services

to at-risk children and families in order to prevent harm to their children.”

N.J.S.A. 30:4C-1.1(a). To accomplish that goal, N.J.S.A. 30:4C-12 authorizes

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New Jersey Division of Child Protection and Permanency v. J.C. and K.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-jersey-division-of-child-protection-and-permanency-v-jc-and-kc-nj-2024.