Colavita v. Virginia Department of Social Services

85 Va. Cir. 51, 2012 WL 9737554, 2012 Va. Cir. LEXIS 165
CourtAugusta County Circuit Court
DecidedMarch 8, 2012
DocketCase No. CL11000486-00
StatusPublished

This text of 85 Va. Cir. 51 (Colavita v. Virginia Department of Social Services) is published on Counsel Stack Legal Research, covering Augusta County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Colavita v. Virginia Department of Social Services, 85 Va. Cir. 51, 2012 WL 9737554, 2012 Va. Cir. LEXIS 165 (Va. Super. Ct. 2012).

Opinion

By Judge Victor V. Ludwig

This matter comes to the Court on an appeal of the decision of the Virginia Department of Social Services (DSS) denying an adoption subsidy for the adoptive child of Appellants, William and Tina Colavita. The Shenandoah Valley Department of Social Services (SVDSS) initially denied the adoption subsidy, and, after a hearing on the matter, DSS sustained SVDSS’s determination in its decision dated February 28, 2011. The Colavitas ask this Court to reverse the DSS hearing officer’s determination that SVDSS properly denied an adoption subsidy.

Brief Summary of Facts and Prior Proceedings

The SVDSS contacted the Colavitas concerning foster placement of a newborn child, Juan. SVDSS informed the Colavitas that it was very probable that Juan would eventually be available for adoptive placement in the Colavitas’ home, but cautioned that eventual adoption was not a certainty. The Colavitas accepted Juan as their foster child, and SVDSS placed Juan in their home in April 2009, only days after his birth on the fourteenth of that month.

[52]*52Prior to placement (and therefore perhaps even prior to Juan’s birth), SVDSS determined that, due to his age, Juan could be placed in a home without an adoption subsidy. As early as May 2009, approximately one month after placing Juan in the Colavitas’ home, SVDSS informed the Colavitas that Juan would not be eligible for an adoption subsidy. The Colavitas responded that they disagreed with that determination and intended to appeal it but nonetheless moved forward with the foster placement with the hope of an eventual adoptive placement. SVDSS personnel even discussed with the Colavitas the procedure for appealing the subsidy determination. Transcript of Hearing held on January 11, 2011, at 25.

The parental rights of Juan’s birth parents were terminated in March 2010. In April 2010, SVDSS sent a letter to the Colavitas informing them once again that, although Juan was now officially available for adoption, he would not be eligible for an adoption subsidy. At this time, however, SVDSS still had not completed an Adoption Assistance Eligibility Form for Juan.

In July 2010, after Juan had been in the Colavitas’ foster care for approximately one year and three months, SVDSS completed an Adoption Assistance Eligibility Form (the Form) for Juan, which concluded that Juan would not be eligible for an adoption subsidy. (The copy of the Adoption Assistance Eligibility Form that is attached to the record of the proceeding below is stamped with the date “AUG 2010.” However, the oral testimony indicates that SVDSS completed the form in July 2010. Transcript, at 5,17.) As nearly as I can ascertain, Sections IV, V, and VI of the form are relevant to the Colavitas’ assignments of error in this case. Section IV requires selecting the means by which the child became eligible for adoption. In Juan’s case, he became eligible by termination of his birth parents’ parental rights on March 26, 2010.

Section V is titled “Basic Eligibility for Virginia Adoption Assistance.” It provides three yes/no questions, and states that each must be checked “yes” in order for the child to be eligible. On Juan’s form, the first two questions, which ask whether the child is under age 18 and whether the child cannot or should not return to the home, are checked “yes.” The final question states:

A reasonable effort has been made to first place the child with an appropriate adoptive parent(s) without providing subsidy or
It has been determined that the child has a significant emotional tie with the prospective adoptive parents while in their care as a foster child or is being adopted by a relative.

Notably, these statements are in the disjunctive. That is, in order to check no, the reviewing agency must find that neither of these conditions is [53]*53present. If either statement is applicable to the child in question, the agency must check “yes.” In Juan’s case, this box was checked “no,” presumably rendering him ineligible for assistance.

I must acknowledge that this criterion contains an ambiguity: it has a set of boxes (for “yes” or “no”) for each part of the disjunctives. Because there are two sets of boxes, and because the instructions say that all criteria must be checked “yes,” one might infer that this inquiry is conjunctive, not disjunctive. For several reasons, however, I find that this interpretation would be flawed. First, the parties, during oral argument in this Court as well as their testimony before the DSS hearing officer, have indicated that the purpose of the emotional ties criterion is to serve as an exception to the requirement for making a reasonable effort to place the child without a subsidy. This view is supported by Virginia Code § 63.2-1300, which states “[a]n exception may be made to the requirement that efforts be made to place the child in an adoptive home without the provision of adoption assistance when the child has developed significant emotional ties with his foster parents while in their care----” This purpose, providing an exception to the otherwise generally applicable requirement to search for a placement without adoption assistance, could only be accomplished by interpreting these criteria in the disjunctive. Second, on the form that SVDSS filled out for Juan, only one of set of the boxes has a check mark. This suggests that even the agency acknowledges that only one box is needed to serve the disjunctive purpose of the inquiry. Finally, the language of the inquiry, by using the word “or,” suggests the disjunctive. All of these factors suggest to this Court that one of the sets of “yes” or “no” boxes on that particular inquiry is superfluous.

Section VI is titled “Special Needs Determination for Adoption Assistance.” Its purpose is to determine whether the child is “hard to place” and therefore eligible for a subsidy. Of the six factors or conditions listed, only one, “The child is a member of a minority or mixed racial heritage,” is checked “yes.” All other factors or conditions are checked “no.” The form is signed by the Colavitas, and their signatures are dated August 3, 2010. Handwritten below their signatures is the following: “Our appeal of this board was acknowledged by those present on 7-28-2010,” which is initialed presumably by one of the Colavitas.

On July 28, 2010, the Colavitas met with SVDSS to discuss Juan’s adoption. The Colavitas brought with them a signed adoption placement agreement dated July 27,2010. The first section of the placement agreement indicates that the Colavitas acknowledged that their adoption of Juan would not include adoption assistance. It states:

We will share our home with this child, assuming responsibility for daily living expenses until the entry of the final order of adoption. It is our understanding that the agency retains [54]*54responsibility for necessary medical coverage and will continue Medicaid until entry of the final order of adoption. After entry of the final order of adoption, we assume complete responsibility for the daily expenses and medical care.

Ms. Colavita indicated that she was “sort of forced” into signing the placement agreement and acknowledging that there would not be a subsidy because SVDSS told her that they would look for another home for Juan if the Colavitas would not agree to take him without a subsidy. Transcript, at 30-31,32-33.

The Colavitas appealed the SVDSS’s adoption assistance eligibility determination to the DSS.

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Related

Jones v. West
616 S.E.2d 790 (Court of Appeals of Virginia, 2005)
School Bd. of County of York v. Nicely
408 S.E.2d 545 (Court of Appeals of Virginia, 1991)
Commissioner, Virginia Department of Social Services v. Fulton
683 S.E.2d 837 (Court of Appeals of Virginia, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
85 Va. Cir. 51, 2012 WL 9737554, 2012 Va. Cir. LEXIS 165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/colavita-v-virginia-department-of-social-services-vaccaugusta-2012.