e-Journal Summary

e-Journal Number : 86035
Opinion Date : 06/22/2026
e-Journal Date : 07/10/2026
Court : Michigan Court of Appeals
Case Name : In re Davis
Practice Area(s) : Termination of Parental Rights
Judge(s) : Per Curiam - Mariani, Murray, and Patel
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Issues:

Child protective proceedings; Removal order; Temporary wardship; Return of child to parent; Mootness; Gleason v Kincaid; Exceptions; In re Detmer/Beaudry

Summary

The court held that respondent-mother’s appeal from the order removing the child from her care was moot. The trial court initially removed the child and placed him in a temporary wardship with his legal father, but while the appeal was pending, it terminated the wardship, returned the child to respondent’s care, and closed the case after an adjudication trial. The court reasoned that an issue is moot when “‘a subsequent event makes it impossible for this Court to grant relief,’” and the only relief respondent sought was return of the child to her care. Because that relief “has already occurred,” the court had no remedy left to provide. It also held that no mootness exception applied because respondent identified no public-significance, recurrence-yet-evasion, or collateral-consequences basis for reaching the merits despite being invited to brief mootness. Dismissed.

Full PDF Opinion