Legal Case

In Re T Caddell Minor

Court

Michigan Court of Appeals

Decided

June 10, 2025

Jurisdiction

SA

Importance

45%

Significant

Case Summary

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports. STATE OF MICHIGAN COURT OF APPEALS UNPUBLISHED June 10, 2025 10:33 AM In re T. CADDELL, Minor. No. 373139 Jackson Circuit Court Family Division LC No. 23-002479-NA Before: MARIANI, P.J., and MALDONADO and YOUNG, JJ. PER CURIAM. Respondent appeals by right the trial court order terminating her parental rights to her minor child, TC. We reverse and remand for further proceedings. I. FACTUAL AND PROCEDURAL BACKGROUND In September 2023, the Department of Health and Human Services (DHHS) filed a petition requesting that the trial court take jurisdiction over TC and remove her from respondent’s care.1 DHHS alleged that respondent lacked suitable housing and was providing improper supervision for TC. DHHS alleged that respondent abused substances, admitted to packaging and selling methamphetamine in the home while TC was present, was involved in several domestic-violence incidents with TC’s father while in TC’s presence, and had a history with Children’s Protective Services (CPS) that resulted in the termination of her parental rights to two other children. The trial court issued an ex parte order immediately removing TC from respondent’s custody and placing her into protective custody under the supervision of DHHS. DHHS placed TC in the care of her adult paternal half-sister immediately after removal. TC remained in this relative placement throughout the ensuing proceedings. The trial court thereafter conducted a preliminary hearing, during which respondent pleaded to the allegations in the petition and to the court’s exercise of jurisdiction. Respondent 1 TC’s father was also a respondent in this case, but he voluntarily relinquished his parental rights to TC in September 2024 and is not involved in this appeal. -1- admitted to ongoing domestic violence with TC’s father in TC’s presence, possessing and using drugs in the home while TC was present, and a prior CPS history, all as detailed in the petition. The trial court accepted respondent’s pleas, authorized the petition, instructed that TC remain in her relative placement, granted respondent parenting time supervised by the relative placement, and ordered DHHS to engage in reasonable efforts toward reunification. DHHS created a case service plan, which the trial court adopted at the initial dispositional hearing in November 2023. At the hearing, the court informed respondent that, in compliance with her case service plan, she must participate in and benefit from domestic-violence, anger- management, mental-health, parenting-education, and substance-abuse services.2 Respondent was also required to complete a psychological evaluation and follow all recommendations from that evaluation, submit to random drug screenings, and obtain and maintain suitable housing. Over the months that followed, respondent struggled to demonstrate consistent progress on her case service plan. During the first few months of the case, respondent consistently attended and acted appropriately at parenting time and demonstrated a strong bond with TC during those visits. In February 2024, however, respondent relapsed and, for a period of time thereafter, demonstrated minimal progress in all areas of concern. For instance, respondent inconsistently attended parenting time and refused to complete drug screens, informing her caseworker that she would test positive for substances. Additionally, although respondent agreed to participate in a two-week detoxification program, she left after two days. Respondent also minimally participated in domestic-violence and parenting-education services; was evicted from her home; and was involved in another serious domestic-violence incident with TC’s father, which resulted in respondent obtaining a personal protection order against him. In April 2024, respondent was arrested for possession of methamphetamine, and she remained in jail for that offense until early June 2024. Immediately following her release from jail, however, respondent participated in a two- month inpatient rehabilitation program, which she successfully completed. Respondent thereafter enrolled in a year-long transitional housing program that provided her with substance-a

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Case Details

Case Details

Legal case information

Status

Decided

Date Decided

June 10, 2025

Jurisdiction

SA

Court Type

federal

Legal Significance

Case importance metrics

Importance Score
Significant
Score45%
Citations
0

Metadata

Additional information

AddedJun 11, 2025
UpdatedJun 11, 2025

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Case Summary

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Court Proceedings

Date FiledJune 10, 2025
Date DecidedJune 10, 2025

Document Details

Times Cited
0
Importance Score
0.5

Legal Classification

JurisdictionSA
Court Type
federal
Judicial Panel
Philip P. Mariani
Allie Greenleaf Maldonado
Adrienne N. Young
Opinion Author
Philip P. Mariani