The trial court in this child protective proceeding improperly conducted an in camera interview with one of the respondent-mother’s children, and this error deprived her of due process, the Michigan Court of Appeals has ruled.

Previously, the Court of Appeals found plain error after the Trial Court held that Respondent-Mother was not entitled to reasonable efforts to reunify her with her children and when it failed to inform Respondent-Mother of her right to appeal the Trial Court’s removal of the children from her care.

The Trial Court plainly erred when it found that Respondent-Mother was not entitled to reasonable efforts to reunify Respondent-Mother with her minor children and when it failed to inform Respondent-Mother of her appellate rights following the Trial Court’s removal of the children from Respondent-Mother’s care.

The Michigan Supreme Court decided on the propriety of a trial court in conducting an in camera interview of a subject child in the context of child protective proceedings.