In re H.D.

CourtWest Virginia Supreme Court
DecidedJune 2, 2023
Docket22-0464
StatusSeparate

This text of In re H.D. (In re H.D.) is published on Counsel Stack Legal Research, covering West Virginia 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 H.D., (W. Va. 2023).

Opinion

No. 22-0464, In re H.D. FILED June 2, 2023 released at 3:00 p.m. EDYTHE NASH GAISER, CLERK Walker, C.J., dissenting, joined by Justice Wooton, SUPREME COURT OF APPEALS OF WEST VIRGINIA

When a circuit court’s order relies on erroneous findings of fact, discretion

does not insulate it from error. The majority has misgivings about the findings of fact here,

footnoting that they are “unduly harsh” characterizations of the record, but, in the name of

deference, does backflips to factually justify an otherwise trumped-up order terminating

parental rights without any evidence sufficient to make the finding that the conditions of

abuse and neglect could not be remedied. For that reason, I dissent, and I am authorized

to state that Justice Wooton joins me.

Going into the dispositional hearing, both the Guardian ad Litem and the

DHHR were recommending that A.T. be put on a post-dispositional improvement period

and maintained that, ultimately, reunification remained in the best interests of the child

even if they could not yet recommend reunification. On the heels of the Guardian ad

Litem’s statement that she would like to see reunification happen and noting that she agreed

with the DHHR’s recommendation of an improvement period, the circuit court abruptly

and inexplicably concluded that continuation in the home of A.T. was contrary to the

welfare and best interests of H.D. and terminated A.T.’s parental rights. It did so even

though the only evidence presented at the dispositional hearing related to whether A.T.

should be granted a post-dispositional improvement period. There was no evidence

1 whatsoever elicited at that hearing relative to disposition, much less enough to satisfy the

DHHR’s burden to establish by clear and convincing evidence there was no likelihood that

the conditions that led to the filing of the petition could be substantially corrected, and the

facts here cannot support such a finding.

The findings that led the circuit court to conclude that the conditions could

not be remedied relied heavily on the “harsh” (in the words of the majority)

characterizations of the record. I take serious issue with the following findings, and I would

find the decisions that flowed from this faulty factual foundation warrant a vacation of the

termination order:

• “At the April 11, 2022, hearing, Adult Respondent [A.T.] admitted

that she is a current drug addict actively using.”

But at the time of the hearing, A.T. was (1) passing drug screens after her

one-time relapse and (2) residing at St. Joseph’s, an inpatient rehab, where it seems unlikely

she was permitted to actively use drugs.

• “The [c]ourt finds that Adult Respondent [A.T.] has failed to show

any success in addressing her methamphetamine use.”

2 On the contrary, A.T. passed more than 70 drug screens after her

adjudication, with only two failures for a single, isolated relapse, after which she again

began producing negative screens and never produced another positive screen.

• “The [c]ourt finds that this case was filed on July 8, 2021, and the only

effort to address her severe drug addiction was entering a rehabilitation

facility on April 12, 2022. The Court finds that during the interim she

continued her illegal drug use and remained an active addict.”

• “The [c]ourt finds that long-term rehabilitation was the most critical

condition of the improvement period due to Adult Respondent [A.T]’s severe

addiction. The Court further finds that for the first eight months of the

improvement period she failed to enter rehab and continued using illegal

drugs.”

According to these findings, a one-time use of methamphetamine that led to

the filing of the petition and a one-time, isolated relapse (for a grand total of two

methamphetamine uses throughout this entire case) constitutes a “severe”

3 methamphetamine addiction, 1 and one can somehow continue active illegal drug use whilst

simultaneously passing dozens upon dozens of drug screens.

And, in the estimation of the circuit court, the outpatient rehab A.T. attended

while waiting to be medically cleared for inpatient rehab and the sixty-day inpatient rehab

seemingly count for nothing. Finally, the circuit court backdates the failure to get into

long-term inpatient rehab for eight months to the beginning of the case as though it is

wholly unexcused, despite that A.T. had an active tuberculosis infection that prevented her

from being admitted to one of those facilities until she was cleared of the infection, which

wasn’t until February 2022.

• “Adult Respondent [A.T.] had a bed at Prestera Center which would

have met the rehabilitation requirement. The Court finds that she told the

center at intake that she did not have a drug problem and was denied

admission. The Court finds that she reported that she was not addicted to

illegal drugs at a time when she clearly was.”

1 The petition against A.T. for methamphetamine use arose from a single use during pregnancy. The ongoing drug addiction references made by both counsel for DHHR and the circuit court may be leveled at A.T.’s opiate addiction developed early in life, but managed through Subutex prescription. Importantly, that was not the basis of the petition filed against her and has no relevance to the basis for termination here.

4 This late-February Prestera encounter pre-dated A.T.’s relapse of March 24-

25, and was at a time when A.T. was passing drug screens and had been passing drug

screens for some seven months, so to say that she was “clearly” addicted to drugs at that

time is an overstatement. Moreover, active use and/or last-use inquiries are well-known

screening criterion for admission into rehabilitation facilities in a state such as ours that

doesn’t have the beds to spare for patients like A.T. who aren’t and haven’t been actively

using. And, as noted below, A.T. testified she was prompted to lie about her drug use to

gain admission to that facility and she refused to do it.

These findings, particularly relative to the failure to enter a long-term rehab

until the “eleventh-hour” are entirely inconsistent with the facts and circumstances of the

case, and, in my view, prompted the circuit court to employ a shoddy “too little, too late”

analysis quick-triggering a termination without evidence sufficient to meet the burden of

proof and without exploring less-restrictive alternatives.

Under other circumstances a “too little, too late” analysis may be an

appropriate basis for termination of parental rights when viewed against the backdrop of

drug use that continued throughout the proceedings. But contrary to the circuit court’s

findings, that simply isn’t what we have here. Notably, the majority opinion doesn’t

reiterate any of those drug use findings in its analysis of termination of rights, nor does it

conclude that the conditions of abuse and neglect were unlikely to be remedied based on

A.T.’s drug use. Instead, it hangs its hat on A.T.’s inability to remedy the conditions in the

5 “near future.” In doing so, the majority maintains the notion that the “too little, too late”

to correct in the “near” future was the result of a totally unexplained eight-month delay in

getting into a long-term rehab when it is undisputed that A.T. had an active tuberculosis

infection that precluded her from inpatient rehabilitation until just before her parental rights

were terminated.

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Related

§ 49-4-604
West Virginia § 49-4-604(c)(5)
§ 49-4-605
West Virginia § 49-4-605
§ 49-4-606
West Virginia § 49-4-606
§ 49-4-610
West Virginia § 49-4-610(3)

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Bluebook (online)
In re H.D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-hd-wva-2023.