## Facts

- Raymond Lamb (defendant/appellant) and Heather Daniels (plaintiff/appellee in the underlying proceeding) had a child, L.M.D., while they were not married.
- The child’s birth certificate named Lamb as the father.
- Lamb executed a paternity acknowledgment under oath.
- A child-support matter against Lamb was filed in the Fort Peck Tribal Court.
- Lamb received proper notice of the child-support matter and notice of the hearing date.
- Lamb did not appear at the hearing.
- The Fort Peck Tribal Court found Lamb to be the child’s father and ordered Lamb to pay child support.
- Lamb appealed to the Fort Peck Court of Appeals, arguing (among other things) that the tribal court improperly found he was the child’s father.

## Issues

1. Whether the Fort Peck Tribal Court erred in adjudicating paternity and ordering child support where the alleged father received proper notice but did not appear, and the record included a birth certificate naming him as father and a sworn paternity acknowledgment.
2. Whether, in this posture, the evidence relied upon by the tribal court (including the birth certificate and sworn acknowledgment) was sufficient to support the paternity determination challenged on appeal.
3. What procedural protections and evidentiary requirements apply in a Fort Peck Tribal Court child-support proceeding when a properly noticed respondent does not attend the hearing.

## Decision

- The Fort Peck Court of Appeals reviewed an appeal from a Fort Peck Tribal Court order that (1) determined paternity and (2) required Lamb to pay child support.
- The reported decision is published at *In re L.M.D.*, 13 Am. Tribal Law 441 (2016).
- Publicly available case-summary material identifies the basic facts, the posture, and Lamb’s appellate challenge to the paternity finding, but it does not provide the full text of the court’s reasoning or the precise disposition language (for example, whether the order was affirmed, reversed, or remanded).

## Legal Principles

- A tribal court may proceed to hear and decide a child-support matter after providing proper notice, even if the responding party does not appear at the scheduled hearing.
- A birth certificate naming a father and a sworn acknowledgment of paternity are key forms of evidence relevant to a paternity adjudication in the context of a support proceeding.
- An appellant challenging a paternity finding entered after nonappearance typically must show legal or procedural error in the trial court’s reliance on the available evidence and the procedures used after notice was given.

## Conclusion

*In re L.M.D.*, 13 Am. Tribal Law 441 (2016), concerns a Fort Peck Tribal Court child-support proceeding in which Raymond Lamb—listed as the father on the child’s birth certificate and having signed a sworn paternity acknowledgment—received proper notice but did not appear, after which the tribal court adjudicated paternity and ordered support; Lamb appealed to the Fort Peck Court of Appeals arguing that the paternity finding (among other aspects of the order) was improper, but publicly available summary information does not provide the opinion’s full reasoning or exact appellate disposition.


In re L.M.D., 13 Am. Tribal Law 441 (2016)