In re Beck
488 Mich. 6
| Mich. | 2010Background
- Respondent's parental rights were terminated under MCL 712A.19b(3)(c)(i), (g), and (j).
- Trial court ordered respondent to continue paying child support after termination.
- Respondent challenged only the continued child-support obligation; termination itself was not challenged.
- Court of Appeals rejected respondent's due-process claim and affirmed the order.
- This Court affirmed, adopting an alternative rationale: parental rights and parental obligations are statutorily separate.
- The statutory framework leaves the support obligation intact unless modified or terminated by a court of competent jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can a parent be ordered to pay child support after rights termination? | Respondent argues support ends with termination. | Court's order to continue support stands; obligation persists. | Yes; support obligation continues unless modified or terminated by a court. |
Key Cases Cited
- In re Beck, 287 Mich App 400 (2010) (recognizes continuation of parental duties post-termination in some contexts)
- Foster v. Wolkowitz, 486 Mich 356 (2010) (discusses child welfare and related duties after termination)
- Hunter v. Hunter, 484 Mich 247 (2009) (terminating rights severs parental rights, but duties may persist)
- Troxel v. Granville, 530 U.S. 57 (2000) (due process considerations in parental rights and child-rearing)