In Re Baby Girl Clausen

On 8 February 1991, Cara Clausen, age 28 and single, gave birth to a baby girl in Cedar Rapids, Iowa. Cara decided she was unable to raise the child on her own and arranged, through an attorney, to have Jan and Roberta DeBoer, who had been desperately trying to adopt for several years, adopt the baby. On 25 February at a routine court hearing, Cara gave the judge a signed release of parental rights. The judge also received a signed release from Cara's boyfriend at the time, Scott Seefeldt, whom Cara named as the baby's father. With all the appropriate steps taken, the judge severed Cara and Scott's parental rights. The DeBoers and the baby returned home to Michigan.

Days later in a sudden change of heart, Cara announced she wanted the baby after all. More significantly, Cara had lied about the identity of the child's father. The actual biological father was Dan Schmidt with whom she had broken up with months before. This revelation meant that while Cara's parental rights had been severed, Dan's had not. With Dan and Cara planning marriage, Cara filed a motion on 6 March to have her daughter returned. Dan did the same a week later. The DeBoers, finally finding a healthy newborn to adopt, maintained they should not be penalized for Cara's erratic behavior. The DeBoers were unable to finalize the adoption as a result of the dispute and legally fought back.

In November of 1991, a district court in Iowa upon hearing the case facts found that Dan Schmidt was the biological father and had not abandoned the child. As a result, the court ruled the adoption void and ordered the child returned by the DeBoers. The DeBoers were granted a legal stay allowing them to keep the child while they appealed the district court's decision. An appellate court affirmed the district court's decision as did the Iowa Supreme Court. In addition, the supreme court maintained that a natural parent's right to custody could not to be disrupted without a showing of parental unfitness which was not established by the DeBoers. With the case returned for trial from the Iowa Supreme Court, the district court in early December of 1992 terminated the DeBoers' right as temporary guardians of the girl.

On the same day their rights were terminated in Iowa, the DeBoers filed a petition in a Michigan circuit court asking the court to assume jurisdiction under the UCCJA. The DeBoers requested the court to find the Iowa custody order not enforceable and return custody back to the them. In response, the Michigan circuit court asserted jurisdiction to determine the best interests of the child. Upon appeal by the Schmidts, the Michigan court of appeals reversed the Michigan circuit court's decision in March of 1993, concluding the Michigan circuit court lacked jurisdiction under UCCJA. The court of appeals also found that, due to the termination of their guardianship, the DeBoers lacked legal standing to challenge the Iowa court order. The DeBoers appealed the case to the Supreme Court of Michigan.