Assumption of jurisdiction under MCL 712A.2(b)(1) & (2); MCL 712A.18f(4); In re AMB; Acceptance of a plea; Conducting a pretrial hearing over Zoom

Noting that the statute on which respondent-father relied in arguing the trial court erred in taking jurisdiction over his children, MCL 712A.18f(4), “has nothing to do with the trial court’s assessment of jurisdiction[,]” the court held that the trial court did not err in accepting his plea. Thus, it affirmed the order of disposition taking temporary jurisdiction over his children. He argued that the trial court erred in doing so “because he appeared not to fully understand his admission at the pretrial hearing, and therefore MCL 712A.18f(4) was not satisfied by clear and convincing evidence.” The court noted that a trial court “may acquire jurisdiction when ‘[a] child comes within the statutory requirements of MCL 712A.2.’” As it stated in AMB, MCL 712A.18f(4) in practice “describes the process by which a family court can enter a dispositional order that provides a child with appropriate care after the family court has determined that the child comes within its jurisdiction.” To the extent respondent claimed the trial court erred in “failing to ‘tak[e] more time to make sure that respondent completely understood what was going on,’” the court rejected this assertion. After reviewing the exchange that included his admission to the allegations in the petition, it determined that he “apparently did not immediately understand one of the questions asked by the trial court, but upon clarification from his attorney, respondent plainly understood the substance of the trial court’s question. In other words, respondent at most did not understand the manner in which the trial court asked the question. Respondent’s acknowledgment of the truth of the allegations in the petition was clearly knowing and intelligent.” As to his statement that he did not waive his right to appear in person, he failed to offer argument or authority, and nothing in the record indicated he “ever objected to holding the pretrial hearing over Zoom, and even on appeal, respondent does not actually argue that his absence from the preliminary hearing or his participation in the pretrial hearing by Zoom caused him any prejudice or provides any basis for reversal.”