Knox v. Lynchburg Division of Social Services

288 S.E.2d 399, 223 Va. 213, 1982 Va. LEXIS 194
CourtSupreme Court of Virginia
DecidedMarch 12, 1982
DocketRecord No. 801789
StatusPublished
Cited by42 cases

This text of 288 S.E.2d 399 (Knox v. Lynchburg Division of Social Services) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Knox v. Lynchburg Division of Social Services, 288 S.E.2d 399, 223 Va. 213, 1982 Va. LEXIS 194 (Va. 1982).

Opinion

CARRICO, C.J.,

delivered the opinion of the Court.

In this case, the trial court terminated the residual parental rights of the mother of three minor children. The principal question presented stems from our 1975 decision in Rocka v. Roanoke Co. Dep’t of Welfare, 215 Va. 515, 211 S.E.2d 76, and the General Assembly’s 1977 enactment of Code § 16.1-283. 1 Specifically, the question is whether § 16.1-283 modifies the Rocka rule that, [217]*217in a contest between a parent and a social service agency, the [218]*218court may not terminate the rights of the parent absent an express finding of parental unfitness.2

The present case involves a girl, born April 14, 1973, and twin boys, born August 24, 1974. Their parents, Dorothy Tweedy Knox and Robert P. Knox, were married in May, 1972.

On January 2, 1975, the father was arrested, and the mother placed the children with Christine Beasley, a family friend who operated a foster care home. At the time, the twins were in “very bad” physical condition. On January 24, the father and mother signed agreements entrusting the children temporarily to the Lynchburg Division of Social Services.

The Beasley home was not an approved foster care facility. However, the Division gave it special approval so the children could remain there, near their parents’ residence.

In February, 1975, the father was sentenced to serve five years in the Virginia penitentiary. During the next year, the mother changed jobs and residences often. Her contacts with the Division were “sporadic” until May, 1977, when they became frequent. In the meantime, the Division was awarded temporary custody of the three children.

In September, 1977, the father was released from prison. He and the mother acquired a place to live, visited the children in the Beasley home, and made plans for the children’s return. In December, however, the parents separated. Thereafter, they appeared in court for “fighting” and were “ordered to stay away from each other.”

In the early months of 1978, based in part on the mother’s complaints, the Division became concerned about conditions in the Beasley home. In an effort to prepare for the children’s return to the mother, the Division had her sign an agreement dated June 2, 1978, which required her to maintain regular contact with her social worker, to visit the children every two weeks, to obtain suitable housing, and to establish financial stability. The agreement stated further that a social worker would counsel the mother regarding sources of employment and housing, provide transportation in seeking work and living quarters, and arrange visits with the children.

[219]*219At the end of June, 1978, the Division removed the mother’s social worker and did not designate a new worker until August. When the new worker was assigned, she arranged to transfer the children from the Beasley home to a foster home in Bedford County, “over twenty miles away.” The change upset the mother because she lacked “ready transportation” to visit the children.

From September until the end of December, 1978, the Division experienced “significant differences and difficulties” with the mother concerning “visits, finances, living quarters and related matters.” In January, 1979, both the mother and the father discussed with the social worker the children’s situation. The father indicated his desire to “give up” the children, but said he was willing for the mother to assume their responsibility. The mother stated she wanted “to get the children back,” but she refused to sign a revised agreement covering “financial and other arrangements” the Division considered necessary for the mother to regain custody.

The conflict between the mother and the Division continued, accentuated by the mother’s failure to return the children to their foster home following an Easter visit. In addition, the mother lost her job at a nursing home and was unable to find fulltime employment.

The Knox’s divorce became final in April, 1979. On May 10, 1979, the father executed an agreement entrusting the children to the Division permanently and authorizing their placement for adoption. When the Division requested the mother to sign a similar agreement, she refused. Later, the Division filed petitions in juvenile and domestic relations district court, seeking termination of parental rights and permission for adoption placement. The petitions were granted, and the mother appealed to the circuit court.

After a hearing on December 13, 1979, the circuit court continued the matter to give the mother an opportunity, with the assistance of a new social worker, to “show progress in her financial and living arrangements.” When the case returned to court on April 7, 1980, it was continued again to permit the mother to pursue the employment plan worked out by her social worker and “to see if further progress in her overall situation could be made.” At a hearing on July 7, 1980, it appeared that the mother “had not pursued the plan” and that her overall situation had not improved.

The circuit court entered orders reciting that termination of parental rights was in the children’s best interests and that the [220]*220mother “without good cause, [had] been unwilling and unable, within a period in excess of five (5) years, to remedy substantially the conditions which led to [the children’s] foster care placement, notwithstanding reasonable and appropriate efforts of social, employment, mental health and other rehabilitative agencies to such end.” The orders terminated the mother’s rights and authorized the Division to place the children for adoption.

As indicated earlier, the principal question for decision is whether the 1977 enactment of Code § 16.1-283 modified the Rocka-Berrien rule that, in a contest between a parent and a social service agency, the rights of the parent may not be terminated absent a specific finding of unfitness.3 The mother contends that a specific finding of unfitness is still required and that, because the trial court made no such finding, it erred in terminating her parental rights.

We disagree with the mother. Rocka and Berrien were decided under Code § 16.1-178, which permitted severance of parental rights if it was “for the child’s best interest and that of the State that such child be separated permanently from its parent, parents or guardian.” In Rocka, we held that a trial court’s finding that an award of permanent custody to a social service agency would promote the child’s best interests was not equivalent to a finding of parental unfitness. Berrien reaffirmed that holding. In both cases, we said that before a court could terminate parental rights, it must find not only the child’s best interests would be served but also that the parent was unfit.

In apparent response to the Rocka and Berrien decisions, the General Assembly repealed § 16.1-178 and replaced it with § 16.1-283. Now, by statute, the court is required to find both that the termination of parental rights will promote the best interests of the child and that certain factors listed in the statute are present. Once the court finds these factors are present, it need not make a further finding of parental unfitness.

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Bluebook (online)
288 S.E.2d 399, 223 Va. 213, 1982 Va. LEXIS 194, Counsel Stack Legal Research, https://law.counselstack.com/opinion/knox-v-lynchburg-division-of-social-services-va-1982.