Rosas v. Children & Family Services

10 Am. Tribal Law 211
CourtColville Confederated Court of Appeals
DecidedJune 26, 2012
DocketNo. AP12-001
StatusPublished
Cited by1 cases

This text of 10 Am. Tribal Law 211 (Rosas v. Children & Family Services) is published on Counsel Stack Legal Research, covering Colville Confederated Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rosas v. Children & Family Services, 10 Am. Tribal Law 211 (Colo. 2012).

Opinion

NELSON, Associate Justice.

This is an appeal from a default judgment arising from an adjudication hearing at which the appellants did not appear at the scheduled time for the hearing. They were, however, represented by spokespersons who were present. We vacate the default judgment and remand for a new adjudication hearing.

PROCEDURAL HISTORY

Marcos Rosas and Kammie Stanger are the parents of two minor children, to wit: T.M. and Z.R. The children were taken [213]*213into protective custody by Children and Family Services of the Colville Confederated Tribes (hereinafter CFS) on December 2, 2011. On December 9, 2011, the tribal court entered an Order from temporary custody hearing giving the care and custody of the children to CFS.

An adjudicatory hearing was scheduled for February 5, 2012. The appellants informed their respective spokespersons that they were on their way to the hearing, but may arrive late. The appellants had not arrived at 9:00 a.m. when the hearing was scheduled to begin. Their respective spokespersons were present. The court granted a ten minute recess and when the appellants had not arrived by 9:25 a.m., the presenting officer moved the court to find them in default and to grant the Petition for Minors in Need of Care. The court found the parents to be in default and adjourned.

The appellants arrived for the adjudicatory hearing “within minutes” after the court had adjourned. They notified the court of their presence, but were informed that the hearing had ended. Subsequently, and without a hearing, the trial court judge entered an Order from Adjudicatory Hearing on March 14, 2012. It included a “Findings and Conclusions” and adjudicated the children as minors in need of care. The Findings and Conclusions stated the parents were in default and that their spokespersons objected to the entry of default on the grounds that they were prepared to proceed in the absence of the parents. The trial court found it in the best interests of the children to remain in the care and custody of CFS “based on the record and applicable law”.

!The appellants moved to set aside the default on the grounds that entry of the | default under the circumstances “was not I appropriate”. The motion to set aside the ¾ default was denied by the trial court on various grounds. E.g. The parents failed to show good cause to set aside the default and the parents needed to personally appear.

The parents filed this as an interlocutory appeal. This is not an interlocutory matter because an adjudication that a child is a minor in need of care is a final order for purposes of appeal. CTC 5-2-261. Accordingly, this matter shall be considered as an appeal from a final order.

STANDARD OF REVIEW

We review findings of fact under the clearly erroneous standard and errors of law de novo. Colville Confederated Tribes v. Naff, 2 CCAR 50, 2 CTCR 08, 22 ILR 6032 (1995); Wiley, et al. v. Colville Confederated Tribes, 2 CCAR 60, 2 CTCR 09, 22 ILR 6059 (1995); Palmer v. Millard, et al., 3 CCAR 27, 2 CTCR 14, 23 ILR 6094 (1996). The issues presented are issues of law and we will review under the de novo standard.

ISSUES

1. Whether the trial court erred when it declared the parents in default when their spokespersons were present and ready to proceed with the adjudicatory hearing.

2. Whether the adjudication of the children as minors in need of care was in error as it was not based upon evidence at an adjudicatory hearing but upon filings and testimony given at a hearing for temporary custody.

3. Whether the Findings and Conclusions were sufficient for the trial court judge to declare by clear, cogent, and convincing evidence that the children were minors in need of care.

[214]*214DISCUSSION

1. Whether the trial court erred when it entered, a default judgment against the parents when their spokespersons were present and ready to proceed.

On February 5, 2011, the parents did not appear at the time set for an adjudicatory hearing. The trial court found the parents in default even though the spokespersons for the parents were present and ready to proceed. The presenting officer moved for an order of default because the parents were not physically present. He justified the motion by stating he wanted to question the parents and their absence justified finding them in default.

The parents’s spokesperson objected by stating that the parents have a right not to testify should they choose, thus the grounds put forward by the presenting officer were without merit. The spokespersons also objected on the grounds that the parents were represented by spokespersons who were present and “stood in the shoes” of the parents; that they were the agents for the parents; and that they were prepared to proceed on their behalf. In other words, the parents were not required to be present for the hearing to proceed.

It is black letter law that an attorney speaks for his client in court in the client’s presence and in his absence. In a matter that considered whether an attorney actually made an appearance for his client, a Washington State case noted that when an attorney makes a formal appearance for a defendant, it is the defendant who appears, and not the attorney. State ex re. Trickel v. Superior Court, 52 Wash. 13, 100 P. 155 (1909). This holds equally true for an attorney present in court when his client is not.

On April 14, 2012, the trial court signed an Order from Adjudicatory Hearing which was, in essence, a default judgment against the parents which found their two children to be minors in need of care.

A default judgment is one of the most drastic actions a court may take. Widicus v. Southwestern Elec. Coop., Inc. 26 Ill.App.2d 102, 167 N.E.2d 799 (1960). They are not favored in law and “it is the policy of the law that controversies be determined on the merits rather than by default.”. Dlouhy v. Dlouhy, 55 Wash.2d 718, 721, 349 P.2d 1073 (1960). The primary test in determining whether a default should be entered is whether justice is being done. “Justice will not be done if hurried defaults are allowed anymore than if continuing delays are permitted. But justice might, at times, require a default or a delay. What is just and proper must be determined by the facts of each case, not by a hard and fast rule.” Widicus, supra at 109, 167 N.E.2d 799. Entry of default judgment granting custody of the parties’ minor child to Mr. Friedlander was an error of law and an abuse of discretion. Clark v. Friedlander, 4 CCAR 55, 2 CTCR 47, 25 ILR 6154, — Am. Tribal Law-(1998).

The trial court erred in declaring the parents in default for failing to appear when their spokespersons were physically present and ready to proceed. The trial court also erred by entering a default judgment (adjudication) without a hearing on the merits of the action. It is just and proper in this matter that an adjudicatory hearing be held.

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Related

Randall v. Children & Family Services
11 Am. Tribal Law 72 (Colville Confederated Court of Appeals, 2012)

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Bluebook (online)
10 Am. Tribal Law 211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rosas-v-children-family-services-colvctapp-2012.