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Polutnik Vs. Dist. Ct. (State, Dep'T Of Family Servs.)

2021-09-17

Summary

Holding. The petition for writ of mandamus is granted, and the district court is directed to vacate the order amending the birth certificate because the court failed to provide notice to the presumed or putative parent and hold an evidentiary hearing before making a parentage determination.

Jeffrey P. challenged a district court order that removed his name from a child's birth certificate during a protective custody proceeding. Although Jeffrey and the child's mother had stipulated in their divorce decree that Jeffrey was not the child's biological father, Jeffrey had continued to act as the child's parent by providing financial support and maintaining visitation. When the Department of Family Services sought to remove the child from the mother's care and moved to amend the birth certificate, the district court granted the motion without notifying Jeffrey or holding a hearing.

The Nevada Supreme Court found that the district court erred because removing a parent's name from a birth certificate constitutes a parentage determination that requires notice to interested parties and an evidentiary hearing. Jeffrey qualified as a presumed or putative parent under state law—the child was born during his marriage and he had openly held the child out as his own. Because the Department of Family Services did not provide Jeffrey notice of the protective custody action or the motion to amend the birth certificate, the court could not proceed without these procedural safeguards.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether removing a parent's name from a birth certificate constitutes a parentage determination requiring notice and hearing
  • Whether a non-biological parent can qualify as a presumed or putative parent
  • Due process requirements for parentage determinations in protective custody proceedings

Procedural posture

Jeffrey P. petitioned the Nevada Supreme Court for a writ of mandamus to overturn a district court order amending the child's birth certificate in a protective custody action.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

IN THE SUPREME COURT OF THE STATE OF NEVADA

JEFFREY P., No. 82363

Petitioner,

vs.

THE EIGHTH JUDICIAL DISTRICT

COURT OF THE STATE OF NEVADA, MEV

IN AND FOR THE COUNTY OF CLARK;

AND THE HONORABLE DAVID S. SEP 1 7 2021

GIBSON, JR., DISTRICT JUDGE, EuzAurri

CLE RUviL !..)0LIRT

Respondents,

DEPUTY CLERX

and

STATE OF NEVADA DEPARTMENT OF

FAMILY SERVICES; LINDA S.; AND

S.S.-P.,

Real Parties in Interest.

ORDER GRANTING PETITION FOR A WRIT OF MANDAMUS

This original petition for a writ of mandamus or prohibition

challenges a district court order removing petitioner Jeffrey P. from the

minor child's birth certificate in a protective custody action.' The child was

born to Jeffrey P. and real party in interest Linda S. during their marriage.

During their divorce proceedings, Jeffrey learned the child was not his

biological child. In the divorce decree, the parties stipulated that the child

was not Jeffrey's biological child, that there are no children who are the

issue of the marriage, and Linda may obtain a new birth certificate for the

child. Linda never amended the child's birth certificate and Jeffrey

'While Jeffrey sought a writ of prohibition in the alternative, a writ

of mandamus is the more appropriate relief because the district court had

jurisdiction to make a parentage determination.

Pursuant to NRAP 34(f)(1), we have determined that oral argument

is not warranted in this appeal.

SUPREME COURT'

Of

NEVADA

101

71- 7(933

remained in the child's life in a parental role by providing financial support

for the child and having summer visitation with the child after Jeffrey

relocated out of the state.

When real party in interest, Department of Family Services

(DFS), removed the child from Linda's care the first time, the child was

placed with Jeffrey until the child could be returned to Linda's care. When

DFS removed the child a second time, it did not give Jeffrey notice of the

protective custody action or its motion to amend the child's birth certificate

in accordance with the divorce decree. The district court granted the motion

to amend the child's birth certificate to remove Jeffrey's name as the child's

father. When Jeffrey learned of that order, he immediately filed a motion

to set it aside and sought to have the child placed with him. The district

court denied the motion to set aside the order but placed the child with

Jeffrey as fictive kin.

Having considered the petition, answers, reply, and supporting

documents, we conclude that writ relief is warranted because the district

court should have held an evidentiary hearing before making a parentage

determination when there was no current parentage information available

and when the party who may oppose the parentage request was not

provided notice of the action. See NRS 34.160 (providing that mandarnus

relief is available to compel the performance of an act that the law requires

as a duty resulting from an office, trust or station, or to control an arbitrary

or capricious exercise of discretion); Intl Garne Tech., Inc. v. Second Judicial

Dist. Court, 124 Nev. 193, 197, 179 P.3d 556, 558 (2008) (same); see also St.

Mary v. Danion, 129 Nev. 647, 649, 309 P.3d 1027, 1029 (2013) (concluding

that the district court erred by not holding an evidentiary hearing in a

disputed parentage matter); Mesi v. Mesi, 136 Nev., Adv. Op. 89, 478 P.3d

SUPREME COURT

OF

NEVADA

2

366, 369 (2020) (explaining that due process requires an interested party be given an opportunity to be heard). While the divorce decree recognized that Jeffrey was not the child's biological father and there were no children as issue of the marriage, it did not conclude Jeffrey was not the child's father. Further, because the divorce decree did not order the birth certificate amended as required by NRS 126.161(2), the district court's order directing the amendment of the birth certificate in the protective custody matter was a parentage determination, which could not occur without notice to Jeffrey and an evidentiary hearing if the parentage request was reasonably opposed.

DFS, the party that filed the motion to amend the birth

certificate, was aware of evidence that would indicate Jeffrey was the child's presumed or putative parent. See NRS 432B.470(2) (requiring notice of a protective custody action be sent to a parent or person responsible for the child's welfare). Jeffrey was still listed as the child's father on the birth certificate at the time of removal and the child was born during Jeffrey and Linda's marriage. See NRS 126.051(1)(a) (providing a man is presumed the father of a child born during the marriage). Additionally, since the divorce decree, Jeffrey had received the child into his home and held the child out as his own. See NRS 126.051(1)(d) (providing a man can be a child's putative parent by receiving the child into his home and openly holding the child out as his own). Thus, no amendment of the birth certificate could be ordered without first providing notice to Jeffrey. See J.D. Constr., Inc. v. IBEX Int? Grp., LLC, 126 Nev. 366, 376, 240 P.3d 1033, 1040 (2010) (explaining that due process requires notice and an opportunity to be heard). Accordingly, the order amending the birth certificate was a parentage determination made without notice to the presumed or putative

3

parent and without adequate evidence. Because the district court thus

erred in granting the motion to amend the birth certificate and in denying

petitioner's motion to set aside that order, we

ORDER the petition GRANTED AND DIRECT THE CLERK

OF THIS COURT TO ISSUE A WRIT OF MANDAMUS instructing the

district court to vacate the order amending the birth certificate.2

AI` , C•J.

Hardesty

14/4(..0

, , J. Sr.J.

Stiglich Gib ons

cc: Hon. David S. Gibson, Jr., District Judge

The Grigsby Law Group

Price Beckstrom, PLLC

Keels Law Group

Attorney General/Carson City

Clark County District Attorney/Juvenile Division

Eighth District Court Clerk

2The Honorable Mark Gibbons, Senior Justice, participated in the

decision of this matter under a general order of assignment. SUPREME COupr

OF

NEVADA

4