Michael Allen Sprouse v. Tiffany Dotson

This appeal requires us to interpret a version of a juvenile court statute effective prior to July 1, 2016. A juvenile court magistrate held a hearing on competing petitions to modify a parenting plan filed by a child’s parents. The magistrate announced her ruling from the bench at the conclusion of the hearing but did not enter a written order until several days later. Mother, dissatisfied with the magistrate’s ruling, filed a request for a rehearing before a juvenile court judge. Mother filed her request within five days of the entry of the magistrate’s order but ten days after the hearing before the magistrate. The juvenile court concluded that mother’s request for rehearing was untimely and confirmed the magistrate’s findings and recommendations as an order of the juvenile court. Because we conclude that the time for requesting a rehearing ran from the entry of the magistrate’s written order, mother’s request for rehearing was timely. Therefore, we reverse.