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Order terminating father's parental rights reversed on court's failure to hold an adjudicative hearing

On reconsideration, the court held that the Michigan Supreme Court's invalidation of the one-parent doctrine, made after the trial court issued its order, "requires that the trial court hold an adjudicative hearing for respondent with respect to his fitness as a parent." Thus, it reversed the termination order and remanded. Because the respondent-father was unable to show that the trial court improperly terminated his rights under § 19b(3)(g), he made a number of procedural claims on appeal, including that the trial court violated his constitutional rights by applying the "one parent doctrine." Though he contested the termination of his parental rights at the dispositional proceeding, he did not receive his own adjudicative hearing. The trial court based its jurisdiction over the child on the basis of the adjudicative hearing on the mother's parental rights. Thus, under Sanders the trial court "must hold an adjudicative proceeding for respondent to determine whether his actions or inactions under MCL 712A.2(b) warrant the exercise of the state's parens patriae authority over his child."

Antenuptial agreement held to be valid and enforceable

The court held that the parties' antenuptial agreement was valid and enforceable, concluding that to invalidate it on the basis of one party's fault would contravene the agreement's clear and unambiguous language, and that as a matter of law, the...

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