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148927 - Helton v Beaman

Matthew Helton,
Kevin Gentry
(Appeal from Ct of Appeals)
(Oakland – Pezzetti, E.)
Lisa Marie Beaman and Douglas Beaman,
Arnold L. Weiner


Defendant Lisa Beaman gave birth to a child in June 2003. At the time, she was in a relationship with Douglas Beaman, whom she later married. Both Lisa and Douglas signed an affidavit of parentage that established Douglas as the child’s father. But later DNA testing established that plaintiff Matthew Helton was the child’s biological father. The DNA testing was performed in 2003, but Helton delayed payment to the DNA laboratory until 2006, and so the parties did not learn of the DNA test results until then.
When the child was nine years old, Helton sued the Beamans under the newly enacted Revocation of Paternity Act, MCL 722.1437 and MCL 722.1443. He supported his suit with an affidavit in which he asserted that the affidavit of parentage was signed under a “mistake of fact,” and that the DNA testing showed that Douglas was not the child’s father. The trial court ruled that, although the DNA test results proved that Helton was the child’s father, the results were not sufficient to establish by clear and convincing evidence that the acknowledgement of parentage should be set aside. After a bench trial, the trial court ruled that Helton did not have a parental relationship with the child, and that it was not in the child’s best interests to grant the relief sought by Helton.
Helton appealed, and the Court of Appeals affirmed in a split published opinion, concluding that the trial court properly denied Helton’s action for revocation of parentage. The majority held that Helton’s affidavit was sufficient to establish a “mistake of fact,” which then allowed the trial court to proceed to determine whether to revoke the acknowledgment of parentage. But the majority agreed with the trial court that Helton was not entitled to relief.  The dissenting judge would have reversed the trial court. Helton established that he was the child’s biological father, noted the dissenter; he was entitled to entry of an order revoking the existing acknowledgment of parentage and to entry of an order of filiation, establishing him as the child’s father.
Helton appealed to the Supreme Court. On September 24, 2014, the Court granted leave to appeal and ordered the parties to include among the issues to be briefed: (1) whether the plaintiff’s affidavit challenging the defendants’ affidavit of parentage was sufficient under MCL 722.1437(2), and specifically, whether the DNA testing results were sufficient to support the allegation that the affidavit of parentage was based on a mistake of fact; (2) whether “paternity determination” in MCL 722.1443(4) includes an acknowledgment of parentage; (3) whether, assuming the sufficiency of the plaintiff’s MCL 722.1437(2) affidavit, the circuit court is always required to consider the best-interest factors of MCL 722.1443(4); (4) whether, if MCL 722.1443(4) does apply, the plaintiff in a revocation of parentage acknowledgment case must bear the burden of proving, by clear and convincing evidence, that revocation is in the best interests of the subject child; and (5) alternatively, whether the equitable doctrine of laches applies here in support of the circuit court’s decision to deny the plaintiff’s request for revocation of the acknowledgment of parentage.