In re M.B. (Justice Trump, concurring)

CourtWest Virginia Supreme Court
DecidedNovember 13, 2025
Docket24-176
StatusSeparate

This text of In re M.B. (Justice Trump, concurring) (In re M.B. (Justice Trump, concurring)) 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 M.B. (Justice Trump, concurring), (W. Va. 2025).

Opinion

FILED No. 24-176 – In re M.B. November 13, 2025 released at 3:00 p.m. C. CASEY FORBES, CLERK TRUMP, Justice, concurring: SUPREME COURT OF APPEALS OF WEST VIRGINIA

I agree with the decision to affirm the circuit court’s order, because it found

that M.B.’s continued placement with his foster family served M.B.’s best interests in a

number of ways. I write separately because I would have limited the scope of this Court’s

review, as well as the reasoning in the opinion, to the narrow issue before the circuit court

in this case: whether continued placement with the foster parents, as a permanency plan for

M.B., was consistent with his best interests. See Napoleon S. v. Walker, 217 W.Va. 254,

259, 617 S.E.2d 801, 806 (2005) (“A fundamental mandate, recognized consistently by this

Court, is that the ultimate determination of child placement must be premised upon an

analysis of the best interests of the child.”); State v. Michael M., 202 W. Va. 350, 358, 504

S.E.2d 177, 185 (1998) (“[A] circuit court must endeavor to secure for a child who has

been removed from his or her family a permanent placement with the level of custody, care,

commitment, nurturing and discipline that is consistent with the child’s best interests.”).

Additionally, I would have found that the circuit court committed harmless error to the

extent that the court’s misapplication of the Supreme Court of the United States’ holding

in Wisconsin v. Yoder (“Yoder”)1 prevented it from considering whether any aspect of

M.B.’s continued placement with the foster parents threatened his best interests.

1 406 U.S. 205 (1972).

1 In its order, the circuit court found that the foster parents would give the child

a “stable loving home,” that the placement would allow the child to “be placed with his

biological siblings,” and that he would “receive a basic education and . . . learn a trade.”

The circuit court made similar findings from the bench:

I find that it is in [M.B.’s] best interest to remain in this placement. There are many reasons for that. This is a stable home. The foster parents love this child. . . . They’ve accepted [M.B. and his three sisters] and want to give these children a home and a family that [the foster father] said could last until eternity. I feel that these children are very fortunate to have foster parents who love them in that way. [M.B.] is in a home with his biological siblings and this is the only family that he has known for his entire life.

However, the circuit court also employed reasoning and relied upon authority that was not

applicable in this case. Specifically, the circuit court made the following findings in its

order, related to the foster parents’ Amish faith, prior to engaging in its analysis of M.B.’s

best interests:

[] That the United States Supreme Court in Wisconsin v. Yoder, 406 U.S. 205 (1972) held that children in an Amish community are exempt from attending high school due to their religious beliefs. .... [] That, after considering all the above, the Court does not believe that it is appropriate to remove the child from this home. [] That the Court does not believe that it can discriminate against this family due to its religion and lifestyle. [] That the United States Supreme Court has given the Amish communities certain entitlements to protection.

The holding of Yoder has no relevance to this case. Yoder involved a constitutional

challenge by Amish parents to Wisconsin’s compulsory school attendance law, which

2 required all children to attend school until the age of sixteen in contravention of “the

fundamental mode of life mandated by the Amish religion.”2 In holding that Wisconsin

could not compel Amish parents to send their children to school beyond the eighth grade,

the Supreme Court made clear that its decision was based on the combination of the

parents’ free exercise rights under the First Amendment to the United States Constitution

(“free exercise rights”) with the parents’ due process rights under the Fourteenth

Amendment to the United States Constitution (“parental due process rights”).3 Without this

confluence, Yoder has no applicability.

The case before us does not involve parental due process rights. Rather, the

circuit court was tasked with deciding whether M.B. should remain in a foster placement

with his foster parents who, like the parents in Yoder, also happen to be Amish. The

similarity between this case and Yoder ends there. Yoder involved a state’s attempt to

2 406 U.S. at 217. 3 406 U.S. at 233-234 (“[W]hen the interests of parenthood are combined with a free exercise claim of the nature revealed by this record, more than merely a reasonable relation to some purpose within the competency of the State is required to sustain the validity of the State’s requirement under the First Amendment. . . . For the reasons stated we hold . . . that the First and Fourteenth Amendments prevent the State from compelling respondents to cause their children to attend formal high school to age 16.”) (emphasis added) (internal quotations and citations omitted). See also Employment Division v. Smith, 494 U.S. 872, 881-882 (1990) (explaining that, generally, cases in which the Court has upheld free exercise challenges to “neutral laws of general applicability” were “hybrid situations” involving “the Free Exercise Clause in conjunction with other constitutional protections, such as . . . the right of parents . . . to direct the education of their children”) (citing Yoder).

3 regulate the choices that parents may make concerning their own children’s education; the

case in front of us does not. Like all persons, foster parents have free exercise rights under

the First Amendment. However, foster parents do not have parental due process rights,

such as the right “to direct the religious upbringing”4 of foster children whom the State

places in their care. Foster children remain in the legal custody of the DHS while they are

in a foster placement,5 and the rights and duties of the foster parents are contractually

defined in an agreement between the foster parents and the DHS.6 As such, Yoder should

not have prevented the circuit court from objectively considering whether any aspect of

M.B.’s foster placement was contrary to his best interests when rendering its decision.

While the circuit court’s misapplication of Yoder appears harmless in this particular case,

this Court should have squarely addressed it, considering that the DHS asks this Court to

4 See 406 U.S. at 233 (recognizing the “rights of parents to direct the religious upbringing of their children”) (citing Pierce v. Society of the Sisters , 268 U.S. 510 (1925)). See also Troxel v. Granville, 530 U.S. 57, 66 (2000) (“[W]e have recognized the fundamental right of parents to make decisions concerning the care, custody, and control of their children.”) (internal citations omitted).

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Related

Pierce v. Society of Sisters
268 U.S. 510 (Supreme Court, 1925)
Wisconsin v. Yoder
406 U.S. 205 (Supreme Court, 1972)
Troxel v. Granville
530 U.S. 57 (Supreme Court, 2000)
State v. Michael M.
504 S.E.2d 177 (West Virginia Supreme Court, 1998)
NAPOLEON S. v. Walker
617 S.E.2d 801 (West Virginia Supreme Court, 2005)
In re G.C.
735 A.2d 1226 (Supreme Court of Pennsylvania, 1999)

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