In re Dependency of A.M.F.

CourtWashington Supreme Court
DecidedMarch 30, 2023
Docket101,270-5
StatusPublished

This text of In re Dependency of A.M.F. (In re Dependency of A.M.F.) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Dependency of A.M.F., (Wash. 2023).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON MARCH 30, 2023 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON MARCH 30, 2023 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

) In the Matter of the Dependency of ) No. 101270-5 ) A.M.F., ) En Banc ) a minor child. ) _______________________________) Filed: March 30, 2023

GONZÁLEZ, C.J.—This case involves three important principles: the State’s

obligation to protect an at-risk child, the parent’s right to parent their child, and the

constitutional prohibition on coercing testimony in criminal cases.

Under our constitution, “[n]o person . . . shall be compelled in any criminal

case to be a witness against himself.” U.S. CONST. amend V. To give force to this

constitutional principle, no person may be compelled to testify in any situation

where their testimony might be used against them in a criminal prosecution, and

the judge or jury in a criminal case may not draw a negative inference from the

defendant’s silence.

In contrast, the trier of fact in a civil case generally may choose to draw a

negative inference from the assertion of the right to remain silent. But while a

negative inference may be drawn, the State may not impose an adverse For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. In re Dependency of A.M.F., No. 101270-5

consequence on a person based solely on their assertion of their right to remain

silent, even in a civil matter.

In this case, a child was removed from his mother and placed with his

grandparents out of concern that she could not care for him. Years later, the State

sought to terminate that mother’s parental rights. On advice of counsel, she

declined to answer questions related to her recent drug use. The trial judge chose

to draw a negative inference from her assertion of that right. We must decide

whether, under the Fifth Amendment, that was permissible. We stress that such a

negative inference must not be the only evidence supporting termination. In this

case, however, it was not error for the court to draw a negative inference from the

mother’s refusal to answer specific questions about her drug use. We affirm the

courts below and remand for any further proceedings necessary to carry out this

decision.

FACTS

YR is the biological mother of AMF. AMF was born with

methamphetamines and opiates in his system. Hospital staff referred AMF to the

Department of Children, Youth, and Family Services. Shortly afterward, YR’s

family met with a social worker and expressed significant concerns about her

ability to care for her son due to ongoing, untreated substance use; her mental

health; and her long-term struggles with housing instability. After AMF finished

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. In re Dependency of A.M.F., No. 101270-5

treatment for withdrawal, YR’s parents took him into their home, where he has

lived his whole life. The record suggests his grandparents wish to adopt him.

Meanwhile, YR’s struggles, particularly with substance abuse, continued through

the dependency.

When AMF was 19 months old, the State petitioned to terminate YR’s

parental rights. At the time of trial, it appears YR was facing criminal charges.

The nature of those charges is not revealed in the record before us. YR testified at

trial but, on the advice of counsel, did not answer questions about the last time she

had used illegal drugs. The trial court agreed YR was entitled to exercise the right

to remain silent, but it warned her that it might draw a negative inference from her

silence.

The court did draw that negative inference, based on that and the other

evidence presented; found the State had met all the statutory factors; and granted

the termination petition. The Court of Appeals affirmed and our commissioner

granted review. The King County Department of Public Defense, Washington

Defender Association, the American Civil Liberties Union of Washington, and the

Washington State Office of Public Defense submitted an amici brief in support of

YR.

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. In re Dependency of A.M.F., No. 101270-5

ANALYSIS

1. Right To Remain Silent

Whether a trial judge may draw a negative inference from a parent’s

assertion of the right to remain silent in a parental rights termination trial is a legal

question we review de novo. See Tomlinson v. Puget Sound Freight Lines, Inc.,

166 Wn.2d 105, 109, 206 P.3d 657 (2009) (citing Ingram v. Dep’t of Licensing,

162 Wn.2d 514, 522, 173 P.3d 259 (2007)). We review challenged findings of fact

for substantial evidence. Id. (citing Ingram, 162 Wn.2d at 522).

Under both our State and federal constitutions, “[n]o person shall be

compelled in any criminal case to give evidence against himself.” WASH. CONST.

art. I, § 9; U.S. CONST. amend. V (“No person . . . shall be compelled in any

criminal case to be a witness against himself.”). These constitutional protections

are a response, in part, to prerevolutionary British investigatory techniques where

people were made to be witnesses against themselves at risk of torture or

damnation. See generally Miranda v. Arizona, 384 U.S. 436, 442-43, 86 S. Ct.

1602, 16 L. Ed. 2d 694 (1966) (quoting Brown v. Walker, 161 U.S. 591, 596-97, 16

S. Ct. 644, 40 L. Ed. 819 (1896)); Katharine B. Hazlett, The Nineteenth Century

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