In Re Nunn , 168 Mich. App. 203 ( 1988 )

T. K. Boyle, J.

(concurring). I agree with the majority’s conclusion that jurisdictional and dispositional hearings may not be combined in the manner that occurred here. MCR 5.908(A) describes the two phases of hearing and provides that the interval between the phases, "if any,” is within the court’s discretion, but may not be more than twenty-eight days (without consent or good cause). This rule supports the conclusion that no particular time need elapse between the two phases, but also indicates that there are distinct phases of the process, each of which must be separately identified. I, therefore, concur in the conclusion that the trial court erred when it failed to designate or identify a portion of the hearing as dispositional.

Having concluded that there was a violation of an integral procedural right, it is unnecessary to reach the issue of whether appellant had actual notice of the allegations that the children were suffering from long-term emotional neglect. Whether and at what point during this "exhaustive adjudicative hearing” appellant had adequate notice of the allegations made against her need not be determined here.