The Michigan Court of Appeals has ruled that requiring a social worker who abuses a child to report that abuse under the Child Protection Law violates the social worker’s right against self-incrimination.

The Court of Appeals vacated the Trial Court’s order terminating mother’s parental rights because mother’s drug use during pregnancy does not qualify as an aggravated circumstance.

The COA held that the defendant was neither a mandatory reporter of child abuse nor did she make the report of child abuse herself, she was still criminally liable for the false report.