In N.J. Div. of Child Prot. & Permanency v. J.Y., the New Jersey Appellate Division began the opinion by stating that “the only thing clear from the record . . . is the confusion regarding the application” at issue. Not a great start. Here, a father had never met his daughter because he was incarcerated when she was born, and her mother did not place his name on the girl’s birth certificate. The father attempted to begin a relationship with the daughter while he was still incarcerated. But when litigation of guardianship issues ensued, there was difficulty transporting the father from jail to the hearing. When the hearing proceeded, it was unclear if all parties were litigating the same issues. Given the procedural morass, the Appellate Division remanded and seemed to issue this opinion more as cautionary instruction than for any precedential value.
