Spaeth v. Warren

478 N.W.2d 319, 1991 Minn. App. LEXIS 1132, 1991 WL 252682
CourtCourt of Appeals of Minnesota
DecidedDecember 3, 1991
DocketC9-91-879
StatusPublished
Cited by16 cases

This text of 478 N.W.2d 319 (Spaeth v. Warren) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spaeth v. Warren, 478 N.W.2d 319, 1991 Minn. App. LEXIS 1132, 1991 WL 252682 (Mich. Ct. App. 1991).

Opinions

OPINION

KLAPHAKE, Judge.

The trial court granted respondent David Spaeth’s motion for summary judgment in a paternity action, basing the adjudication on the concession of Ann Hiegel, the child’s mother, that Spaeth is the child’s biological father. Hiegel appeals from the judgment, raising issues of proper parties to the action, best interests of the child, visitation, and appearance of parties at a motion hearing.

FACTS

Appellant Ann Hiegel and respondent David Spaeth dated from April-August 1987. Hiegel admits that Spaeth is the only man with whom she had sexual intercourse during that time. During July 1987, Hiegel conceived a child, M.J.W., who was born on May 6, 1988.

In December 1987, Spaeth was convicted of second degree burglary and began serving a 38-month prison sentence. Spaeth was released from prison in December 1989. He is currently a college, student at St. Cloud State University and works part-time as a nursing assistant. Hiegel has refused contact with Spaeth since before. MJ.W.’s birth, and Spaeth has never visited or provided support for M.J.W.

Hiegel married Mark Hiegel in August 1990. Mark Hiegel treats M.J.W. as his own son. In October 1990 Mark Hiegel filed a petition to adopt M.J.W.

While in prison, Spaeth initiated a paternity action to have himself declared the father of M.J.W. Based on the fact that Spaeth’s paternity is undisputed, the trial court granted Spaeth’s motion for summary judgment, adjudicating Spaeth to be MJ.W.’s father. Spaeth did not appear in person at the motion hearing. The court concluded that Spaeth was entitled to reasonable visitation and owed M.J.W. a duty of support, and that there was no “reasonable purpose” for appointing M.J.W. a guardian ad litem at that time. However, the court did not set visitation or child support and reserved jurisdiction over those issues. Hiegel appeals, contending; (1) M.J.W. and Mark Hiegel should have been made parties to the action (2) the court should have considered MJ.W.’s best interests in determining paternity (3) the court erred in stating Spaeth was entitled to reasonable visitation (4) the record should be corrected to reflect that Spaeth [321]*321did not personally appear at the motion hearing.

ISSUES

1. Did the trial court abuse its discretion in declining to join M.J.W. and Mark Hiegel as parties to the paternity action?

2. Did the trial court err in failing to consider MJ.W.’s best interests in determining paternity?

3. Did the trial court err in concluding that David Spaeth is entitled to visitation?

4. Did the trial court err in stating that David Spaeth personally appeared at the summary judgment motion?

ANALYSIS

I.

On appeal from summary judgment, this court reviews the record to determine whether issues of material fact exist and whether the trial court erred in its application of the law. Niccum v. Hydra Tool Corp., 438 N.W.2d 96, 98 (Minn.1989).

Hiegel contends that M.J.W. and Mark Hiegel should have been named as parties to the paternity action under the parentage act, Minn.Stat. §§ 257.51-.74 (1990). Under Minn.Stat. § 257.60 (1990), “[t]he child may be made a party to the action.” Thus, the determination whether to join a child as a party is usually discretionary. See Minn.Stat. § 645.44, subd. 15 (Supp.1991) (“may” is permissive when used in statutes); Minn.R.Civ.P. 21. However, the parentage act specifically requires the child to be made a party whenever:

an action to declare the existence of the father and child relationship is brought by a man presumed to be the father * * * or a man who alleges to be the father, and the mother of the child denies the existence of the father and child relationship.

Minn.Stat. § 257.60(3) (1990). This language does not apply here. Although Spaeth is the presumed father, Hiegel does not deny the existence of the father and child relationship. She concedes that Spaeth is MJ.W.’s biological father. See Minn.Stat. § 257.52 (1990) (father and child relationship refers only to “biological or adoptive father”).

Hiegel asserts that case law requires that children be joined in paternity actions, citing Johnson v. Hunter, 447 N.W.2d 871 (Minn.1989). Johnson concerned whether res judicata barred a child from bringing a separate paternity action where the mother’s paternity action against the same man had been dismissed with prejudice. Id. at 874. Johnson is thus factually distinguishable from this case because it concerned the issue of whether the child could initiate a separate paternity action rather than whether a child could join such an action. Id. at 872. Moreover, Johnson contained a more compelling reason for requiring a child to be joined as a party since denial of the right to bring a separate action would have meant that paternity could not have been established. In allowing the child in Johnson to pursue a separate action, the court noted the desirability of requiring children to be joined in paternity actions and suggested that the legislature consider amending permissive language regarding joinder of children. Id. at 875. That the legislature has thus far failed to do so is further evidence that joinder under these circumstances is permissive and not mandatory.

Here, MJ.W.’s interests were adequately addressed in Spaeth’s action, especially since issues of visitation and child support were not determined. We conclude the trial court did not abuse its discretion in declining to join M.J.W. as a party.

Hiegel also claims that Mark Hiegel should have been named a party to the action under Minn.Stat. § 257.55, subd. 1(d) (1990) because he met the criteria to be a presumed father. Mark Hiegel would be presumed M.J.W.’s biological father if

[wjhile the child is under the age of majority, he receives the child into his home and openly holds out the child as his biological child.

[322]*322Id. This section must be construed liberally, to achieve its “remedial and humanitarian purposes.” Larson v. Schmidt, 400 N.W.2d 131, 134 (Minn.App.1987) (quoting Weber v. Anderson, 269 N.W.2d 892, 894-95 (Minn.1978)).

While Mark Hiegel has received M.J.W. into his home, he has not held M.J.W. out as his biological child. He has encouraged M.J.W. to call him “Daddy” and has, commendably, provided him financial and emotional support. However, he has taken no action to assert paternity at any time, and M.J.W. does not use his surname. See Pierce v. Pierce, 374 N.W.2d 450, 451 (Minn.App.1985) (man not presumed father where, among other reasons, he “took no action to claim paternity”), pet. for rev. denied (Minn. Nov. 4, 1985). Mark Hiegel’s decision to petition to adopt M.J.W. rather than pursue a paternity adjudication shows he did not hold himself out to be MJ.W.’s biological father.

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Spaeth v. Warren
478 N.W.2d 319 (Court of Appeals of Minnesota, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
478 N.W.2d 319, 1991 Minn. App. LEXIS 1132, 1991 WL 252682, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spaeth-v-warren-minnctapp-1991.