In re Clausen

In Iowa on February 8, 1991, Cara Clausen, who was unmarried, gave birth to a child, and she claimed that Scott Seefeldt was the child’s father. Clausen relinquished her parental rights on February 10, 1991, and Seefeldt relinquished his rights on February 14, 1991. The child was placed with foster parents Roberta and Jan DeBoer (defendants), who were Michigan residents. On February 25, 1991, in an Iowa court, the DeBoers filed a petition to adopt the child. The Iowa court terminated the parental rights of Seefeldt and Clausen and granted temporary custody of the child to the DeBoers. The child continued to reside in Michigan with the DeBoers. On March 9, 1991, Clausen moved the Iowa court to revoke her relinquishment of parental rights, and she disclosed that Daniel Schmidt, not Seefeldt, was the child’s father. Weeks later, Schmidt petitioned to intervene in the DeBoers’ Iowa adoption matter. Trial was held in November 1991, and the court issued its findings in December: Schmidt was the biological father, the DeBoers did not carry their burden of proof that Schmidt had abandoned the child or that his parental rights should be terminated, and therefore a best-interests-of-the-child analysis would be premature. The court held that the termination of Schmidt’s parental rights was void, and the DeBoers’ petition for adoption was denied. The matter reached the Iowa Supreme Court, which affirmed the trial court’s ruling. The Iowa court ordered the DeBoers to appear on December 3, 1992, but the DeBoers did not obey its order. The trial court terminated the DeBoers’ rights as temporary guardians of the child and ruled that the DeBoers were acting outside a legal claim to her custody. On the same day, the DeBoers petitioned a Michigan trial court to assume jurisdiction under the Uniform Child Custody Jurisdiction Act, to enjoin the enforcement of the Iowa order and either find that the Iowa order was unenforceable or modify the order. The Michigan court entered an ex parte temporary restraining order that left the child in the DeBoers’ custody and forbade Schmidt from removing the child from the county. Schmidt moved the Michigan court to dissolve the preliminary injunction and to recognize and enforce the Iowa order. The Michigan trial court ruled against Schmidt, the Michigan Court of Appeals reversed the trial court’s ruling, and the matter reached the Michigan Supreme Court.