NJSBA Family Law Section

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  • 1.  Appeal of DCPP "Established" Finding

    Posted 07-30-2015 02:25 PM
    Does anyone know if and how you can appeal or challenge a DCPP finding of "Established" for abuse or neglect? I am aware that a finding of "Substantiated" can be administratively appealed to the Office of Administrative Law but I am assuming an "Established" finding is an easy way out for DCPP since it seems impossible to challenge or question their conclusions. No complaint has been filed by DCPP. I am concerned about this finding being used against my client in a pending custody/divorce matter.

    Kathleen P. Stockton, Esq.

    One Centennial Square
    Haddonfield, NJ 08033
    Direct Dial: 856-616-2604
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  • 2.  RE: Appeal of DCPP "Established" Finding

    Posted 07-30-2015 02:34 PM
    You can appeal an "established" finding by the agency the same way that all agency appeals are taken – directly to the appellate division. From there, you will receive the discovery underlying the established finding and may opt to supplement the record in response to the factual record contained in the investigation summary and related documents.

    If there is a legitimate factual dispute, there may be a remand to the agency to develop a factual record (i.e., to give you the administrative hearing that you would otherwise receive if the finding was substantiated). Alternatively, the Appellate Division may decide on the merits that the finding was not supported by the record and/or was arbitrary, capricious and unreasonable.

    But you will not know whether to seek to supplement the record, seek a reman and based upon factual disputes or contest the sufficiency of the legal determination made by the agency until you receive the statement of items comprising the record on appeal after filing the notice of appeal.

    Allison C. Williams

    Sent from my iPhone




  • 3.  RE: Appeal of DCPP "Established" Finding

    Posted 07-30-2015 02:39 PM
    It is my understanding that "Established" cannot be appealed because it does not place the person on the Child Abuse Registry. When the Division changed their possible findings a year or so ago, to include "established" and "not established," they made sure this was the case. I always say -- they have way too much power! The orders and especially the documents from a DCPP (DYFS) case should not be part of any divorce or custody battle because those are protected documents not to be attached to motions or other filings in other matters. Of course, we still see them from time to time and must argue against it.



    Carol A. Weil, RN, JD
    Attorney at Law
    1405 Chews Landing Rd., Ste. 8
    Laurel Springs, NJ 08021
    (856) 352-0050
    Fax: (856) 352-0276




  • 4.  RE: Appeal of DCPP "Established" Finding

    Posted 07-30-2015 05:53 PM

    I am a pool attorney for the Office of Parental Representation and I have this very issue on appeal in the Appellate Division.  It has been fully briefed and is waiting for oral argument.  Another staff attorney in OPR Appellate also has this issue in the App. Div. and that case may also be fully briefed at this point.  Our position is that a finding that abuse and neglect has been "established" is, according to the Division's own regulations,  a finding by a preponderance of the evidence, that abuse and/or neglect has occured.    What differentiates it from a substantiated finding is the absence of some aggravating factors that are enumerated in the rules.  Bear in mind that the "preponderance of the evidence" finding is made by an investigator who is not even an atttorney and the App. Div. has commented in dicta in cases that this, in and of itself, is concerning.  Our position also is that the regs and the public comment and inquiry pursuant to the adoption of the new rules do not make it absolutely clear that an established finding does not place you on the child abuse registry.  The App. Div. has noted that there are certain situations where the fact that an investigation occurred may be disclosed without disclosing the finding.  This in itself can be harmful.  Our position is that this is a consequence of magnitude entitling the parent to a hearing.  In addition, we consider the "established" finding an agency determination that is entitled to direct appeal to the App. Div. under R. 2:2-3(a)(2).  The problem with that is you don't have a record to appeal.  But case law says that in that situation, the App. Div. remands back to court (usually the Law Div., but here it would be chancery) to develop a record.  These are our arguments, we'll see where they go.

    In your circumstances, I don't know where you want to go with this and how far you want to take it.  I would definitely challenge the use of this finding in your divorce action, considering the lack of due process in the manner in which the determination was made.  Your client had no opportunity to challenge that finding.  If your client is concerned with being branded a perpetrator of child abuse (notwithstanding the Division's assurances that the finding is not discloseable, which as I said above I am not absolutely sure about), then he or she may want to try to challenge this further.  So, the way I would approach this is I would file the appeal papers with DCPP.  It will be rejected, of course.  I would then make a motion for a hearing directly to the Director.  That will be denied, too, but then you will have this denial to appeal to the App. Div., in addition to the initial agency investigation. 

    Feel free to call me.  I can send you my brief off line so that you can understand the law and regs involved.

    Clara

    ------------------------------
    Law Office of
    Clara S. Licata, Esq.
    55 Harristown Rd.
    Suite 302
    Glen Rock, NJ 07452
    201-612-1170
    Fax 201-612-1179
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  • 5.  RE: Appeal of DCPP "Established" Finding

    Posted 07-30-2015 06:08 PM
    Hi all....I am also an OPR Pool Attorney and have been for 20 years. I stand corrected as we were told differently back when the new labels started. I don't want to be a pain, but will you please send me (or the whole group) a copy of the opinion when the case ends? The Division in Gloucester County has been offering clients a Title 30 "family in need of services" in lieu of a fact-finding in "established" cases but the catch is that they want a promise under oath that the client will not attempt to appeal the "established" finding. This list is great....always learning something. I also do appeals for OPR Appellate and have not seen this appealed. Thanks. Carol




  • 6.  RE: Appeal of DCPP "Established" Finding

    Posted 07-30-2015 07:38 PM

    Kathleen,

    Another thing I forgot to mention in my prior post.  The Division will use this "established" finding as an aggravating factor to bump up a future referral to a "substantiated."  In my case, they stated their position is that the parent gets the due process on the "established" finding by appealing the subsequent "substantiated" finding. This raises a host of questions as to how this happens.  Is there a hearing within the hearing to adjudicate the "established" appeal within the "substantiated" appeal?  What if time has passed and you lose witnesses on the established finding.  If you are in a matrimonial proceeding and your client's spouse is seeking to use this to advantage, maybe spouse makes a new referral and this "established" finding gets considered in the new referral.    I would give serious consideration to trying to appeal this. 

    Clara

    ------------------------------
    Law Office of
    Clara S. Licata, Esq.
    55 Harristown Rd.
    Suite 302
    Glen Rock, NJ 07452
    201-612-1170
    Fax 201-612-1179
    ------------------------------