In The Matter Of The Parental Rights To A.r.

CourtCourt of Appeals of Washington
DecidedJuly 29, 2024
Docket85483-6
StatusUnpublished

This text of In The Matter Of The Parental Rights To A.r. (In The Matter Of The Parental Rights To A.r.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In The Matter Of The Parental Rights To A.r., (Wash. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of the Parental No. 85483-6-I Rights of: DIVISION ONE A.R. UNPUBLISHED OPINION

SMITH, C.J. — A.R. was removed from the care of her parents shortly after

birth. She has had no contact with her father, E.R., since then. In September

2022, the Department of Social and Health Services (the Department) petitioned

to terminate E.R.’s parental rights. The Department’s multiple attempts to serve

E.R. personally by process server and then by certified mail were unsuccessful.

Following these attempts at service, the court granted the Department’s request

to serve E.R. by publication. E.R.’s counsel appeared at the termination trial but

E.R. did not, despite further attempts to reach him. At the conclusion of the trial,

the court terminated E.R.’s parental rights. E.R. appeals, asserting that he never

received proper notice of the termination petition. We disagree and affirm.

FACTS

Shortly after A.R. was born, she was removed from her parents’ care due

to substance abuse by both parents. A.R. has had no contact with her father,

E.R., since she was discharged from the hospital after birth. In January 2019,

the court established dependency as to E.R by default. The dependency order

placed A.R. in licensed foster care pending the investigation of relative No. 85483-6-I/2

placement options. She was later placed with her maternal aunt, who had

already adopted her half-brother.

Jamie Driscoll, the social worker assigned to A.R.’s dependency case,

attempted to stay in contact with E.R. through the course of the dependency

proceedings but received little to no response. E.R. rarely responded to

Driscoll’s attempts to communicate, nor did he complete any of the offered

services.

In September 2022, the Department filed a petition to terminate E.R.’s

parental rights to A.R. The Department noted E.R.’s lack of contact with A.R.,

the fact that he did not know about her needs or how to care for her, and the lack

of any improvement in his longstanding parenting deficiencies despite years of

offered services.

Between September and October 2020, the Department attempted to

personally serve E.R. with the petition seven times at the address listed for him in

the State Enforcement Management System (SEMS) – Division of Child Support

records. Each attempt was unsuccessful. The process server reached E.R. by

phone on one attempt and E.R. provided a time frame during which he would be

home. E.R. did not return home during that window. At no point did E.R. deny

living at his listed address.

The Department next attempted to serve E.R. notice of the petition by

certified mail, using the same address. E.R. received notice of the attempt to

deliver the mail but failed to pick up the certified mail packet. The postal service

returned the certified mail packet as undeliverable.

2 No. 85483-6-I/3

Given the extent of the unsuccessful attempts to serve E.R. personally or

by mail, the Department sought court authorization to serve notice by publication.

The court granted the Department’s request based on various declarations

detailing the numerous attempts to serve and to locate E.R. and notify him of the

petition. This included documentation of searches of Department databases and

the “jail registry.” Following the court order, the Department published a notice

and summons in the Seattle Daily Journal of Commercial Commerce.

E.R.’s attorney, Dennice Bryant, appeared at the May 2023 dependency

trial following the service by publication. The court paged E.R. in the courtroom

and over Zoom but he did not respond. Bryant moved to withdraw based on

E.R.’s absence but the court denied the motion, noting that it did not want E.R. to

be entirely unrepresented.

The trial court heard testimony from Driscoll and the court appointed

special advocate (CASA) on the merits of the Department’s petition. Bryant

cross-examined both witnesses. Relying on Driscoll and the CASA’s testimony,

the trial court terminated E.R.’s parental rights to A.R. The court determined that

E.R. had not answered the petition after service by publication and deemed the

allegations in the petition admitted. The court also explicitly found that the

testimony and evidence supported findings necessary for the termination of

E.R.’s parental rights under RCW 13.34.180(1) and RCW 13.34.190(1) and (2).

E.R. appeals the termination of his parental rights, asserting only that he

did not receive legal notice of the Department’s termination petition.

3 No. 85483-6-I/4

ANALYSIS

Standard of Review

We review alleged due process violations and sufficiency of service of

process claims de novo. In re Welfare of L.R., 180 Wn. App. 717, 723, 324 P.3d

737 (2014); In re Dependency of G.M.W., 24 Wn. App. 2d 96, 114, 519 P.3d 272

(2022), review denied, 1 Wn.3d 1005 (2023).

Notice

E.R. asserts that the Department did not properly notify him of the

termination proceedings because he did not receive personal service. The

Department contends that service by publication comported both with E.R.’s due

process rights and the dependency statute. We agree with the Department.

“Parental termination proceedings are accorded strict due process

protections.” In re Interest of Darrow, 32 Wn. App. 803, 806, 649 P.2d 858

(1982). Strict due process requires notice that is “ ‘reasonably calculated, under

all the circumstances,’ to apprise the parties of the pendency of the action and

enable them to present a defense.” In re Welfare of H.S., 94 Wn. App. 511, 525,

973 P.2d 474 (1999) (quoting Duskin v. Carlson, 136 Wn.2d 550, 557, 965 P.2d

611 (1998)). Default termination may proceed once proper notice is given. In re

Welfare of S.I., 184 Wn. App. 531, 543, 337 P.3d 1114 (2014).

A party to a termination proceeding must be personally served if personal

service is possible. RCW 13.34.070(8). If the party cannot be personally served,

but their address is known or can be determined with reasonable diligence, the

party may be served by certified mail. RCW 13.34.070(8). And if neither

4 No. 85483-6-I/5

personal service nor service by certified mail is possible, the court may authorize

service by publication. RCW 13.34.080(1), (2).

Personal service may be accomplished by delivering a copy of the

summons to the party personally or leaving a copy at the party’s place of “usual

abode” with a person of “suitable age and discretion” who similarly lives in the

home.

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Related

Duskin v. Carlson
965 P.2d 611 (Washington Supreme Court, 1998)
Darrow v. Department of Social & Health Services
649 P.2d 858 (Court of Appeals of Washington, 1982)
Duskin v. Carlson
136 Wash. 2d 550 (Washington Supreme Court, 1998)
In re the Welfare of L.R.
324 P.3d 737 (Court of Appeals of Washington, 2014)
In re the Welfare of S.I.
337 P.3d 1114 (Court of Appeals of Washington, 2014)
B.S. v. Department of Social & Health Services
973 P.2d 474 (Court of Appeals of Washington, 1999)

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