In Re Williams Minors, 372081

The Michigan Department of Health and Human Services (Petitioner) filed a petition seeking court jurisdiction over the Williams minors, citing neglect and unfit home environment after one child died and another tested positive for drugs at birth.
The petition detailed the medical circumstances of the deceased child, including failure to monitor a trach tube, but did not include specific allegations regarding the welfare of the surviving children.
Evidence at hearing included testimony about the condition of the home (described as messy and unclean), prior CPS investigations (all closed after correction), and the lack of respondent cooperation with a drug screen.
The trial court found that the evidence presented supported issues related only to the decedent and not the surviving children; there was little information about the condition or care of the other minors at the time of the petition.
The court denied jurisdiction, concluding the statutory burden of proof was not met as to the surviving Williams minors.
The Department appealed the denial of jurisdiction.

Issue	Petitioner Argument	Respondents Argument	Held
Did the trial court err in denying jurisdiction based on neglect and unfit home environment?	Past neglect and unfit conditions, anticipatory neglect warranted jurisdiction.	Conditions concerned only the decedent; no present harm or imminent risk to the other minors shown.	Court affirmed denial: insufficient evidence for other children's risk.
Should anticipatory neglect doctrine apply given past neglect of the deceased child?	Doctrine allows inference from harm to one child to siblings, especially with prior CPS history.	Siblings had different circumstances; evidence did not show risk to them.	Not applicable here due to differences; doctrine requires more fact-specific similarity.
Was the state of the parents’ home a sufficient ground to take jurisdiction?	Clutter and presence of drugs/alcohol demonstrated risk and unfitness.	Messy home not legally sufficient for unfit environment absent more egregious conditions.	Clutter alone does not amount to unfit home under statute.
Was the evidence sufficient to establish neglect of surviving minors under MCL 712A.2(b)(1)?	Evidence about decedent and past CPS suggests ongoing neglect.	No specific evidence of neglect or harm regarding surviving children.	No preponderance of evidence of neglect toward other children.

In re BZ, 264 Mich App 286 (Mich. Ct. App. 2004) (sets standard for jurisdictional findings in child protection)
In re Utrera, 281 Mich App 1 (Mich. Ct. App. 2008) (distinguishes adjudicative vs. dispositional phase in child protective proceedings)
In re Long, 326 Mich App 455 (Mich. Ct. App. 2018) (clutter alone is not sufficient evidence for unfit home)
In re Kellogg, 331 Mich App 249 (Mich. Ct. App. 2020) (explains anticipatory neglect doctrine and its limitations)
In re Gazella, 264 Mich App 668 (Mich. Ct. App. 2005) (abuse of one child not required to take jurisdiction over siblings)