In the Matter of the Welfare of the Children of: A. M. C., T. D. R., and A. J. J., Jr., Parents., A16-282

Background

Wright County petitioned to terminate the parental rights of A.M.C. (mother) and the fathers to three children (M.C., P.J., J.C.); the county later sought guardianship/placement for the children.
M.B., paternal grandmother of two children, intervened and sought transfer of legal and physical custody of all three children; children were initially placed with M.B. but later moved to nonrelative foster care.
The parents (mother and one father) voluntarily consented to termination; the remaining dispute at trial was whether M.B. should receive permanent custody.
The district court conducted a trial, heard testimony both favorable and critical of M.B.’s suitability (including concerns about the children’s substantial emotional/behavioral needs and M.B.’s willingness/ability to prevent parental contact), and requested proposed findings from the parties.
The district court adopted most of the county’s proposed findings verbatim but attached its own detailed appendix describing the evidence; it found M.B. had not shown she could meet the children’s complex needs and denied the transfer petition.
On appeal M.B. argued the court improperly adopted the county’s findings, made erroneous fact-findings, abused discretion in best-interests analysis, and failed to give proper weight to the familial relationship; the Court of Appeals affirmed.

Issues

Issue	Plaintiff's Argument (M.B.)	Defendant's Argument (County/District Court)	Held
Whether the district court erred by largely adopting the county’s proposed findings verbatim	Adoption suggests the court did not exercise independent judgment; reversal warranted	Court supplemented adopted findings with a detailed independent appendix and exercised discretion	No error; verbatim adoption permissible where court independently assessed evidence
Whether specific fact-findings (awareness of children’s needs; risk of parental contact; household adult criminals) were clearly erroneous	Findings lack record support; M.B. showed ability and willingness to care for children and to prevent parent contact	Court credited testimony (caseworker, GAL) that M.B. minimized children’s needs and was unlikely to prevent contact with father/other adults	Findings were supported by the record except for one clerical confusion about which adult son lived with M.B.; error was harmless
Whether the district court abused its discretion in concluding transfer was not in children’s best interests	Court failed to consider or gave little weight to witnesses and statutory factors (religion, community, talents)	Court considered statutory best-interest factors, found little evidence on some points, and acted within broad discretion	No abuse of discretion; best-interests determination upheld
Whether the court failed to consider the familial relationship or improperly downgraded relative-placement preference	Statutory and precedent-based preference for placement with relatives requires stronger consideration/favoring of M.B.	Current statute requires consideration of relatives but does not impose a presumption or preference; relative status was considered among other factors	No error; district court considered familial relationship but prioritized ability to meet children’s complex needs

Key Cases Cited

In re Children of T.A.A., 702 N.W.2d 703 (Minn. 2005) (courts prefer independent findings but verbatim adoption not per se reversible)
In re Welfare of S.S.W., 767 N.W.2d 723 (Minn. App. 2009) (broad district-court discretion in child-protection matters)
In re Welfare of R.T.B., 492 N.W.2d 1 (Minn. App. 1992) (appellate courts defer to district court credibility determinations)
In re Children of T.R., 750 N.W.2d 656 (Minn. 2008) (standard for clearly erroneous fact-findings)
In re Welfare of Child of A.H., 879 N.W.2d 1 (Minn. App. 2016) (best-interests review is for abuse of discretion)
In re Welfare of Children of D.F., 752 N.W.2d 88 (Minn. App. 2008) (weight of testimony is for the factfinder)
In re Welfare of M.M., 452 N.W.2d 236 (Minn. 1990) (discussed historical relative-placement preference)
In re S.G., 828 N.W.2d 118 (Minn. 2013) (context on relative-placement preference changes in adoption context)