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Appeals, Family Law, Social Services Law

FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT).

The First Department determined Family Court gave proper consideration to the Americans with Disabilities Act (ADA) in evaluating the termination of parental rights. The main issue raised at the permanency hearing was “to what degree the [foster care] agency was required to accommodate the parents’ cognitive disabilities when discharging its obligation to pursue the goal of return to parent.” The First Department also found that the mootness exception applied to the appeal (the issue is likely to come up again):

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While Family Court correctly determined that the ADA is not applicable to this proceeding (see Matter of La’Asia Lanae S., 23 AD3d 271 [1st Dept 2005]), the law makes clear, as Family Court recognized and the parties in this case agreed, that “the agencies’ efforts towards a permanency plan must be tailored to the particular circumstances and individuals in a given case” … . As the Family Court held in La’Asia  … (91 Misc 2d 28, 42-43 …) , in the context of termination of parental rights actions, a court may properly look to the ADA’s standards for guidance in evaluating whether “diligent efforts” were made by the agency under Social Services Law § 384-b(7). The Family Court here acknowledged that it was required to consider the mother’s special needs when determining if the agency’s efforts were reasonable in this case. After evaluating the agency’s efforts in that light, the court found that the agency satisfied its obligation to tailor its efforts to the mother’s needs … and that the agency’s reunification efforts were reasonable under the circumstances … .

In precluding litigation of ADA claims during the permanency hearing, but considerate of its purpose to guide the reasonable efforts analysis, the Family Court properly complied with the requirements as set forth by the court in the La’Asia case. Matter of Lacee L. (Stephanie L.–Dekodia L.), 2017 NY Slip Op 06418, First Dept 9-12-17

 

FAMILY LAW (FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT))/PARENTAL RIGHTS (FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT))/APPEALS (MOOTNESS EXCEPTION, FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT))/MOOTNESS EXCEPTION  (APPEALS, FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT))/AMERICANS WITH DISABILITIES ACT (ADA)  (FAMILY COURT EXERCISED THE PROPER LEVEL OF CONSIDERATION OF THE AMERICANS WITH DISABILITIES ACT IN THIS TERMINATION OF PARENTAL RIGHTS PROCEEDING, THE MOOTNESS EXCEPTION APPLIED TO THE APPEAL (FIRST DEPT))

September 12, 2017
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Constitutional Law, Family Law, Religion

RELIGIOUS LIFESTYLE RESTRICTIONS PLACED UPON MOTHER VIOLATED HER CONSTITUTIONAL RIGHTS, FATHER’S DESIRE TO RAISE AND EDUCATE THE CHILDREN IN THE HASIDIC TRADITION WAS IN THE CHILDREN’S BEST INTERESTS (SECOND DEPT).

The Second Department, in a full-fledged per curiam opinion, determined that a change in circumstances warranted a modification of the stipulation of settlement of a divorce action. The opinion is too detailed to fairly summarize here. At issue was the extent of the religion-related requirements of the stipulation of settlement. Father objected to the lifestyle changes associated with mother’s open acknowledgment that she is gay and the presence of O, a transgender man, in the home. The court held that the religion-based restrictions placed upon mother’s lifestyle, stemming from Supreme Court’s finding that the religious aspects of the stipulation were paramount, violated her constitutional rights. Rather than the religious concerns, the analysis must focus on the best interests of the children. To that end, the Second Department determined certain aspects of the stipulation concerning the father’s desire to raise and educate the children in the Hasidic tradition were in the children’s best interests:

… [T]he Supreme Court improperly directed that enforcement of the parties’ stipulation of settlement required the mother to practice full religious observance in accordance with the Hasidic practices of ultra Orthodoxy during any period in which she has physical custody of the children and at any appearance at the children’s schools. Although the court accepted the father’s argument that the religious upbringing clause “forb[ids] [the mother from] living a secular way of life in front of the children or while at their schools,” the plain language of the parties’ agreement was “to give the children a Hasidic upbringing” … . The parties’ agreement does not require the mother to practice any type of religion, to dress in any particular way, or to hide her views or identity from the children. Nor may the courts compel any person to adopt any particular religious lifestyle … . * * *

Contrary to the mother’s contention, the weight of the evidence demonstrates that it is in the children’s best interests to continue to permit the father to exercise final decision-making authority over the children’s education and to continue to permit him to require the children to practice full religious observance in accordance with the Hasidic practices of ultra Orthodoxy while they are in his custody, or in the custody of a school that requires adherence to such practices. Weisberger v Weisberger, 2017 NY Slip Op 06212, Second Dept 8-16-17

FAMILY LAW (RELIGIOUS LIFESTYLE RESTRICTIONS PLACED UPON MOTHER VIOLATED HER CONSTITUTIONAL RIGHTS, FATHER’S DESIRE TO RAISE AND EDUCATE THE CHILDREN IN THE HASIDIC TRADITION WAS IN THE CHILDREN’S BEST INTERESTS (SECOND DEPT))/CUSTODY (FAMILY LAW, RELIGIOUS LIFESTYLE RESTRICTIONS PLACED UPON MOTHER VIOLATED HER CONSTITUTIONAL RIGHTS, FATHER’S DESIRE TO RAISE AND EDUCATE THE CHILDREN IN THE HASIDIC TRADITION WAS IN THE CHILDREN’S BEST INTERESTS (SECOND DEPT))/CONSTITUTIONAL LAW (RELIGION, FAMILY LAW, RELIGIOUS LIFESTYLE RESTRICTIONS PLACED UPON MOTHER VIOLATED HER CONSTITUTIONAL RIGHTS, FATHER’S DESIRE TO RAISE AND EDUCATE THE CHILDREN IN THE HASIDIC TRADITION WAS IN THE CHILDREN’S BEST INTERESTS (SECOND DEPT))/RELIGION (FAMILY LAW, CUSTODY, CONSTITUTIONAL LAW, RELIGIOUS LIFESTYLE RESTRICTIONS PLACED UPON MOTHER VIOLATED HER CONSTITUTIONAL RIGHTS, FATHER’S DESIRE TO RAISE AND EDUCATE THE CHILDREN IN THE HASIDIC TRADITION WAS IN THE CHILDREN’S BEST INTERESTS (SECOND DEPT))

August 16, 2017
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Family Law

CHILD WAS ENTITLED TO A FINDING THAT REUNIFICATION WITH HIS MOTHER IN EL SALVADOR WAS NOT VIABLE DUE TO PARENTAL NEGLECT (SECOND DEPT).

The Second Department, reversing Family Court, over a dissent, determined the child was entitled to a finding that reunification with his mother in El Salvador would not be viable in this special juvenile immigrant status proceeding:

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… [W]here, as here, the Family Court’s credibility determination is not supported by the record, this Court is free to make its own credibility assessments and overturn the determination of the hearing court … . Based upon our independent factual review, we conclude that the record supports a finding that reunification of the child with his mother is not a viable option based upon parental neglect. The record reflects that the mother failed to meet the educational needs of the child… . The child testified that, although he was prevented from attending school by gang members who beat him while walking to school, the mother did not arrange for transportation, which was within her financial means, but instead, told him to stay home. Additionally, the child was expelled from one school due to excessive tardiness, and he failed the seventh grade … . Further, the mother did not provide adequate supervision, often leaving the then eight-year-old child home alone at night in the neighborhood where he had encountered the gang violence … . …

​

Since the record is sufficient for this Court to make its own findings of fact and conclusions of law, we find that reunification of the child with one or both of his parents is not viable due to parental neglect … . Matter of Dennis X.G.D.V., 2017 NY Slip Op 06080, Second Dept 8-9-17

 

FAMILY LAW (SPECIAL JUVENILE IMMIGRANT STATUS, CHILD WAS ENTITLED TO A FINDING THAT REUNIFICATION WITH HIS MOTHER IN EL SALVADOR WAS NOT VIABLE DUE TO PARENTAL NEGLECT (SECOND DEPT))/SPECIAL JUVENILE IMMIGRANT STATUS (FAMILY LAW, CHILD WAS ENTITLED TO A FINDING THAT REUNIFICATION WITH HIS MOTHER IN EL SALVADOR WAS NOT VIABLE DUE TO PARENTAL NEGLECT (SECOND DEPT))

August 9, 2017
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Evidence, Family Law

CHILD ABUSE ALLEGATIONS SUPPORTED BY A PREPONDERANCE OF THE EVIDENCE, NO NEED TO DEMONSTRATE WHICH OF THE TWO RESPONDENTS ABUSED THE CHILD (FIRST DEPT).

The First Department determined the child abuse allegations against mother and grandmother (respondents) were supported by a preponderance of the evidence. It was not necessary to prove which of them abused the child (Syriah):

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The evidence submitted on petitioner’s direct case supports the court’s finding that respondents abused Syriah by showing that, while she was in their care, Syriah suffered an injury that would not ordinarily occur absent an act or omission of the person responsible for her care … .”[Petitioner] was not required to establish whether the mother or the [grandmother] actually inflicted the injuries, or whether they did so together”… .

A preponderance of the evidence supports the court’s conclusion that Syriah’s injuries were inflicted and not accidentally caused. She suffered a traumatic brain injury, which resulted in anoxic ischemic encephalopathy and subdural hematoma, from which she died. Doctor Cahill, a pediatrician qualified as an expert in child abuse pediatrics, opined to a reasonable degree of medical certainty that Syriah’s injuries were the result of a shaking event. Among other things, Syriah had no skull fracture, and, as one expert testified, without a skull fracture, the most likely explanation for subdural hemorrhage and anoxic change is vigorous shaking.

Respondents failed to demonstrate that Syriah’s injuries “could reasonably have occurred accidentally” so as to rebut petitioner’s prima facie showing of abuse … . The testimony of petitioner’s experts ruled out the possibility that the injuries were caused, as respondents contend, by a short fall from a mattress to the floor. Indeed, respondents’ own experts testified that it would be “unusual” and “extremely rare” for a child to suffer the injuries that Syriah suffered from a short fall.  Matter of Syriah J. (Esther J.), 2017 NY Slip Op 06048, First Dept 8-8-17

 

FAMILY LAW (CHILD ABUSE, EVIDENCE, CHILD ABUSE ALLEGATIONS SUPPORTED BY A PREPONDERANCE OF THE EVIDENCE, NO NEED TO DEMONSTRATE WHICH OF THE TWO RESPONDENTS ABUSED THE CHILD (FIRST DEPT))/EVIDENCE (FAMILY LAW, CHILD ABUSE ALLEGATIONS SUPPORTED BY A PREPONDERANCE OF THE EVIDENCE, NO NEED TO DEMONSTRATE WHICH OF THE TWO RESPONDENTS ABUSED THE CHILD (FIRST DEPT))/CHILD ABUSE (FAMILY LAW, EVIDENCE, CHILD ABUSE ALLEGATIONS SUPPORTED BY A PREPONDERANCE OF THE EVIDENCE, NO NEED TO DEMONSTRATE WHICH OF THE TWO RESPONDENTS ABUSED THE CHILD (FIRST DEPT))

August 8, 2017
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Family Law

FAMILY COURT HAD THE POWER TO RETROACTIVELY DISMISS A NEGLECT PETITION AND IMPOSE A SUSPENDED JUDGMENT AFTER MOTHER DEMONSTRATED THE ABILITY TO CARE FOR HER CHILDREN (FIRST DEPT).

The Second Department, in a full-fledged opinion by Justice Renwick, in a matter of first impression, determined that Family Court had the power to retroactively impose a suspended judgment and dismiss a neglect petition. Mother had consented to a neglect finding but subsequently turned her life around and demonstrated the ability to care for her four children:

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This Family Court Act article 10 child neglect proceeding raises an issue of apparent first impression for this Court: whether the Family Court properly granted respondent mother a suspended judgment, “retroactively,” in order to vacate a neglect finding and dismiss a neglect proceeding. Initially, the mother consented to a neglect finding and the Family Court’s dispositional order released the children to the mother, under the supervision of petitioner, Administration for Children Services (ACS), for 12 months. At the end of this period, upon satisfactorily completing the terms of the dispositional order, the mother made a postdisposition motion to modify the dispositional order. The court granted a suspended judgment, retroactively, due to the mother’s compliance with the conditions of the dispositional order, and vacated the neglect finding, as consistent with the children’s best interest. [W]e find not only that the Family Court Act permits such a retroactive remedy, but that the remedy served the children’s best interest under the circumstances of this case. Matter of Leenasia C. (Lamarriea C.–Maxie B.), 2017 NY Slip Op 06050, First Dept 8-8-17

FAMILY LAW (NEGLECT, FAMILY COURT HAD THE POWER TO RETROACTIVELY DISMISS A NEGLECT PETITION AND IMPOSE A SUSPENDED JUDGMENT AFTER MOTHER DEMONSTRATED THE ABILITY TO CARE FOR HER CHILDREN (FIRST DEPT))/NEGLECT (FAMILY COURT HAD THE POWER TO RETROACTIVELY DISMISS A NEGLECT PETITION AND IMPOSE A SUSPENDED JUDGMENT AFTER MOTHER DEMONSTRATED THE ABILITY TO CARE FOR HER CHILDREN (FIRST DEPT))

August 8, 2017
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Family Law

AFTER MOTHER CONSENTED TO A NEGLECT FINDING AND THE CHILD WAS PLACED IN KINSHIP FOSTER CARE, MOTHER SHOULD NOT HAVE BEEN AWARDED UNSUPERVISED VISITATION WITHOUT A HEARING 2ND DEPT.

The Second Department, reversing Family Court, determined mother should not have been awarded unsupervised visitation without a hearing. Mother had previously consented to a neglect finding and the child had been placed in kinship foster care:

“In a child protective proceeding pursuant to Family Court Act article 10, [t]he best interests of the children determine whether visitation should be permitted to a parent who has committed abuse or neglect. Pursuant to Family Court Act § 1061, the court may modify any order issued during the course of a child protective proceeding for good cause shown.’ As with the initial order, the modified order must reflect a resolution consistent with the best interests of the children after consideration of all relevant facts and circumstances”…  “Before making children available for unsupervised visits, a Family Court must find that a person with a history of abuse or neglect of her children has successfully overcome her prior inclinations and behavior patterns, despite what may be the best of intentions”… . Where facts material to a best interests analysis, and the circumstances surrounding such facts, remain in dispute, a hearing is required … .

Under the circumstances of this case, a hearing was necessary to determine whether unsupervised overnight visitation between the mother and the child was in the child’s best interests … . Matter of Jeanette V. (Marina L.), 2017 NY Slip Op 05741, 2nd Dept 7-19-17

FAMILY LAW (VISITATION, AFTER MOTHER CONSENTED TO A NEGLECT FINDING AND THE CHILD WAS PLACED IN KINSHIP FOSTER CARE, MOTHER SHOULD NOT HAVE BEEN AWARDED UNSUPERVISED VISITATION WITHOUT A HEARING 2ND DEPT)/VISITATION (FAMILY LAW, AFTER MOTHER CONSENTED TO A NEGLECT FINDING AND THE CHILD WAS PLACED IN KINSHIP FOSTER CARE, MOTHER SHOULD NOT HAVE BEEN AWARDED UNSUPERVISED VISITATION WITHOUT A HEARING 2ND DEPT)/NEGLECT (VISITATION, AFTER MOTHER CONSENTED TO A NEGLECT FINDING AND THE CHILD WAS PLACED IN KINSHIP FOSTER CARE, MOTHER SHOULD NOT HAVE BEEN AWARDED UNSUPERVISED VISITATION WITHOUT A HEARING 2ND DEPT)

July 19, 2017
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Family Law

NO PRESUMPTION THE BEST INTERESTS OF A CHILD ARE SERVED BY PLACEMENT WITH A FAMILY MEMBER, FAMILY COURT REVERSED (2ND DEPT).

The Second Department, reversing Family Court, determined that it was not in the best interests of the children to be removed from foster care and placed with family members:

“When considering guardianship appointments, the child’s best interests are paramount” … . Once parental rights have been terminated, there is no presumption favoring the child’s biological family over the proposed adoptive parents selected by an authorized agency … .

Here, the Family Court’s determination that it was in the children’s best interests to grant the respective petitions for guardianship, rather than keeping the children with their foster parents for the purpose of adoption, lacks the requisite sound and substantial basis in the record … . The children Hailey and Kailyn have resided in the same foster home since June 2015, and the children Danielle and Belicia have resided in the same foster home since November 2015, where they have bonded with their foster parents and are happy, healthy, and well provided for … . There is no presumption that the children’s best interests will be better served by returning them to a family member, and it would not be in the children’s best interests to do so here … . Matter of Rebecca B. v Michael B., 2017 NY Slip Op 05720, 2nd Dept 7-19-17

FAMILY LAW (ADOPTION, GUARDIANSHIP, NO PRESUMPTION THE BEST INTERESTS OF A CHILD ARE SERVED BY PLACEMENT WITH A FAMILY MEMBER, FAMILY COURT REVERSED (2ND DEPT))/ADOPTION (GUARDIANSHIP, NO PRESUMPTION THE BEST INTERESTS OF A CHILD ARE SERVED BY PLACEMENT WITH A FAMILY MEMBER, FAMILY COURT REVERSED (2ND DEPT))/GUARDIANSHIP (ADOPTION, NO PRESUMPTION THE BEST INTERESTS OF A CHILD ARE SERVED BY PLACEMENT WITH A FAMILY MEMBER, FAMILY COURT REVERSED (2ND DEPT)

July 19, 2017
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Criminal Law, Evidence, Family Law

EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT.

The Second Department, under a weight of the evidence analysis, determined the evidence of the appellant’s liability as an accomplice in this juvenile delinquency proceeding was insufficient. The complainant testified appellant was present during the assault and theft by another. Presence is not enough:

A determination premised upon accessorial liability requires proof beyond a reasonable doubt that the accused acted with the mental culpability necessary to commit the act charged and that, in furtherance thereof, he solicited, requested, commanded, importuned, or intentionally aided the principal to commit such act… . “A person’s mere presence at the scene of the crime, even with knowledge of its perpetration, cannot render him or her accessorially liable for the underlying criminal conduct” … .  Here, we agree with the appellant that the Family Court’s finding of accessorial liability was against the weight of the credible evidence. The appellant is alleged to have been an accomplice with another youth who punched the complainant in the face and took his iPhone. However, at the fact-finding hearing, when asked about the appellant’s actions at the time of the assault and robbery, the complainant testified that the appellant was standing near the perpetrator and watched the incident occur. The presentment agency’s evidence with respect to the crimes of robbery in the second degree, robbery in the third degree, grand larceny in the fourth degree, and attempted assault in the third degree established only that the appellant was present at the scene of the offense… . Accordingly, the determination of the Family Court with respect to those crimes was against the weight of the evidence, and the order of disposition must be modified accordingly. Matter of Justin M., 2017 NY Slip Op 05605, 2nd Dept 7-12-17

FAMILY LAW (JUVENILE DELINQUENCY, EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT)/JUVENILE DELINQUENCY (FAMILY COURT, EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT)/CRIMINAL LAW (FAMILY LAW, JUVENILE DELINQUENCY, EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT)/EVIDENCE (JUVENILE DELINQUENCY, EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT)/ACCESSORIAL LIABILITY  (JUVENILE DELINQUENCY, EVIDENCE OF ACCESSORIAL LIABILITY INSUFFICIENT IN THIS JUVENILE DELINQUENCY PROCEEDING, PRESENCE IS NOT ENOUGH 2ND DEPT)

July 12, 2017
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Family Law

EVEN ONE INSTANCE OF EXCESSIVE CORPORAL PUNISHMENT IS SUFFICIENT TO SUPPORT A NEGLECT FINDING 2ND DEPT.

The Second Department, affirming Family Court, noted that even one instance of excessive corporal punishment is sufficient support for a neglect finding:

“Although parents have a right to use reasonable physical force against a child in order to maintain discipline or to promote the child’s welfare, the use of excessive corporal punishment constitutes neglect” … Even “a single incident of excessive corporal punishment is sufficient to support a finding of neglect” … .

Here, contrary to the father’s contention, a preponderance of the evidence supported the Family Court’s finding that the father neglected the subject child by inflicting excessive corporal punishment … . The father admitted that on June 17, 2014, he hit the child once with a wooden ruler, and other credible evidence established that the child sustained visible marks and swelling on his left forearm as a result, and that this was not an isolated incident … . Matter of Tarelle J. (Walter J.), 2017 NY Slip Op 05600, 2nd Dept 7-12-17

FAMILY LAW (EVEN ONE INSTANCE OF EXCESSIVE CORPORAL PUNISHMENT IS SUFFICIENT TO SUPPORT A NEGLECT FINDING 2ND DEPT)/NEGLECT (FAMILY LAW, EVEN ONE INSTANCE OF EXCESSIVE CORPORAL PUNISHMENT IS SUFFICIENT TO SUPPORT A NEGLECT FINDING 2ND DEPT)/CORPORAL PUNISHMENT (FAMILY LAW, NEGLECT, EVEN ONE INSTANCE OF EXCESSIVE CORPORAL PUNISHMENT IS SUFFICIENT TO SUPPORT A NEGLECT FINDING 2ND DEPT)

July 12, 2017
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Family Law, Social Services Law

PUTATIVE FATHER’S REQUEST FOR A DNA PATERNITY TEST SHOULD NOT HAVE BEEN DENIED 2ND DEPT.

The Second Department, reversing Family Court, determined putative father’s request for a DNA paternity test should not have been denied:

… [T]he Orange County Department of Social Services filed a paternity petition against the appellant on behalf of the mother of the subject child, alleging him to be the father of the child, who was born in 2007. The appellant requested a genetic marker test, commonly known as a DNA test. After a hearing, the Family Court determined that the appellant was estopped from contesting paternity, in effect, denied his application for a DNA test, and entered an order of filiation adjudicating the appellant to be the father of the child.

Contrary to the Family Court’s determination, the appellant should not have been estopped from contesting his paternity of the child. Considering the lack of a relationship between the appellant and the child, there was no evidence that “the child would suffer irreparable loss of status, destruction of her family image, or other harm to her physical or emotional well-being” if the DNA test were administered and it was ultimately shown that the appellant was not the biological father of the child … .

Accordingly, we cannot conclude that a genetic marker test of the appellant’s and the child’s DNA would be contrary to the best interests of the child. Commissioner of Social Servs. v Dorian E.L., 2017 NY Slip Op 05590, 2nd Dept 7-12-17

FAMILY LAW (PATERNITY, PUTATIVE FATHER’S REQUEST FOR A DNA PATERNITY TEST SHOULD NOT HAVE BEEN DENIED 2ND DEPT)/PATERNITY (PUTATIVE FATHER’S REQUEST FOR A DNA PATERNITY TEST SHOULD NOT HAVE BEEN DENIED 2ND DEPT)/DNA TEST (PUTATIVE FATHER’S REQUEST FOR A DNAPATERNITY TEST SHOULD NOT HAVE BEEN DENIED 2ND DEPT)

July 12, 2017
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