Personal jurisdiction; Service; MCL 712A.13; In re Brown; Distinguishing In re Mayfield & In re Dearmon

Holding that the trial court never obtained personal jurisdiction over respondent-mother due to the lack of strict compliance with MCL 712A.13, the court reversed the order of adjudication and remanded. While respondent “appeared at some of the adjudication proceedings, and it was averred that she received the amended petition by e-mail, the statute was not followed because she was never personally served, nor was alternative service in accordance with the statute provided.” The court noted that in Brown, it concluded that the lack of personal service “rendered the proceedings void, even though the respondent had actual notice of the proceedings and appeared at them.” In contrast to Mayfield, in this case there were no attempts to reach respondent at her last-known address. And in contrast to Dearmon, “not only was the original petition not personally served on respondent[], it also contained no allegations against her.”