Helton v. Beaman
304 Mich. App. 97
| Mich. Ct. App. | 2014Background
- Revocation of Paternity Act action challenging defendants’ acknowledgment of parentage for a nine-year-old raised by Beaman and his wife.
- DNA testing in 2003-2006 showed Helton is the child’s biological father, but defendants believed Douglas was the father when signing the affidavit.
- The circuit court held DNA results alone were not sufficient to revoke the acknowledgment and denied relieft.
- Helton’s affidavit alleged mistake of fact, misconduct, and fraud as grounds for revocation; credibility determinations favored defendants.
- The court applied best-interest factors to deny revocation, but the majority concludes those factors were misapplied; the DNA results are not binding and other factors may govern under the Revocation of Paternity Act.
- Helton ultimately appeals, and the majority affirms the circuit court’s result on different grounds; a concurrence agrees Moiles misapplied the law and argues for best-interest analysis under the RPA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Helton’s affidavit was sufficient to proceed | Helton’s affidavit showed mistake of fact; DNA proves paternity. | Defendants’ belief of Douglas as father at signing defeats misconduct/fraud grounds. | Yes; sufficiency for mistake of fact established. |
| Whether DNA results binding governs revocation | DNA proves non-paternity and supports revocation. | DNA results are not binding; other factors control. | DNA results not binding; requires broader analysis. |
| Whether best-interest factors apply in revocation under RPA | Best-interest factors should guide whether to revoke. | Moiles precludes using best-interest factors in this context. | Best-interest factors may apply; Moiles is criticized by concurrence. |
| Whether laches bars Helton’s action | Delay unnecessary; timely action sought justice for child. | Delay prejudices Beaman and child; laches applies. | Laches applies; action barred. |
Key Cases Cited
- Moiles, In re Moiles, 303 Mich App 59 (2013) (disallows best-interest analysis under the Revocation of Paternity Act for revocation of acknowledgment)
- Nugent, Bay Co Prosecutor v. Nugent, 276 Mich App 183 (2007) (affidavit sufficiency; clear and convincing standard; equity considerations)
- In re AP, 283 Mich App 574 (2009) (change-of-custody framework; burden-shifting and established custodial environment)
- Sinicropi v Mazurek, 273 Mich App 149 (2006) (establishes paternity through acknowledgment; rights and duties of child)
- Aichele v Hodge, 259 Mich App 146 (2003) (acknowledgment of parentage establishes paternity; rights conferred)