SER WV Department of Human Services v. The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County.

CourtWest Virginia Supreme Court
DecidedMarch 25, 2025
Docket24-728
StatusPublished

This text of SER WV Department of Human Services v. The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County. (SER WV Department of Human Services v. The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County.) 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
SER WV Department of Human Services v. The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County., (W. Va. 2025).

Opinion

STATE OF WEST VIRGINIA SUPREME COURT OF APPEALS FILED State of West Virginia ex rel. March 25, 2025 West Virginia Department of Human Services, released at 3:00 p.m. C. CASEY FORBES, CLERK Petitioner, SUPREME COURT OF APPEALS OF WEST VIRGINIA

v.) No. 24-728

The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County, Respondent.

MEMORANDUM DECISION

Shortly after the West Virginia Department of Human Services (“DHS”) announced that it would close the West Virginia Children’s Home (“Children’s Home”), the Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County, entered an administrative order directing DHS to continue operating the Children’s Home. In this case, DHS seeks a writ of prohibition to prevent the enforcement of Judge Wilmoth’s administrative order.1 By order entered December 26, 2024, this Court stayed Judge Wilmoth’s administrative order and granted DHS’s motion for expedited relief. The matter was submitted for consideration without oral argument. Acting without undue delay, we determine that a memorandum decision issuing the writ of prohibition is appropriate to resolve the issue in an expedited manner.

The Children’s Home is a juvenile residential facility located in Randolph County, West Virginia, that is more than 100 years old. Currently, the aging facility is able to accommodate no more than seven male juveniles, and by the end of October 2024, it housed only two juveniles. According to DHS, the facility costs approximately $1.7 million annually to operate, and a study completed about one year ago identified $7.8 million in necessary maintenance and safety measures to bring the building up to code. Noting the facility’s age and structural needs, DHS announced on November 19, 2024, that it would close the Children’s Home effective December 31, 2024. In anticipation of this closure, DHS worked with Children’s Home personnel to transition them to other employment, and nurses providing on-call services were given their contractually required thirty-day cancellation notice. DHS also planned for the two juveniles residing at the Children’s Home to remain there until they completed their school semester, at which point they would be transferred to an appropriate alternative placement by December 31, 2024.

1 DHS appears by Attorney General John B. McCuskey, Deputy Attorney General Director Steven R. Compton, and Assistant Attorney General Kristen E. Ross. Judge Wilmoth appears by Teresa J. Lyons.

1 On December 9, 2024, approximately three weeks after the announcement of the Children Home’s closure, Judge Wilmoth unilaterally entered an “Administrative Order” directing the Children’s Home to “remain open to receive placement of and provide housing, care, treatment, education, safety and other required and necessary services to the juveniles of this State.”2 Judge Wilmoth found that closing the Children’s Home would “result in further risk and harm to juveniles,” would deny them services to which they are entitled by statute, exacerbate difficulties placing juveniles, and amounts to an “abdication of” DHS’s statutory requirement to provide juvenile housing and treatment. Judge Wilmoth ordered DHS to operate the Children’s Home “until such time as there exists within this State adequate and appropriate housing and treatment to address and provide for the many and various needs of at-risk juveniles in this State as set forth by statute.” Judge Wilmoth did not identify a source of legal authority permitting him to mandate the continued operation of the Children’s Home. The administrative order states only that “West Virginia Code 49-2-101 et[] seq.[] outlines the obligations of the State of West Virginia regarding the issues raised by the current conditions in this state” and that the Children’s Home “serves in the capacity of meeting some or all of these obligations.” On December 11, 2024, DHS filed this petition for a writ of prohibition seeking to prohibit Judge Wilmoth from enforcing the administrative order.3

West Virginia Code § 53-1-1 provides that “[t]he writ of prohibition shall lie as a matter of right in all cases of usurpation and abuse of power, when the inferior court has not jurisdiction of the subject matter in controversy, or, having such jurisdiction, exceeds its legitimate powers.” Where it is claimed that a court has exceeded its legitimate powers, we examine five factors:

(1) whether the party seeking the writ has no other adequate means, such as direct appeal, to obtain the desired relief; (2) whether the petitioner will be damaged or prejudiced in a way that is not correctable on appeal; (3) whether the lower tribunal’s order is clearly erroneous as a matter of law; (4) whether the lower tribunal’s order is an oft repeated error or manifests persistent disregard for either procedural or substantive law; and (5) whether the lower tribunal’s order raises new and important problems or issues of law of first impression.[4]

“These factors are general guidelines that serve as a useful starting point for determining whether a discretionary writ of prohibition should issue[,] . . . all five factors need not be satisfied, [and]

2 Although only two juveniles remained in the Children’s Home, the administrative order was entered in six separate juvenile matters: four juvenile status offender cases, one juvenile delinquency case, and one child abuse and neglect proceeding. The administrative order was later filed in a non-juvenile proceeding opened by the circuit court. 3 DHS also moved Judge Wilmoth to vacate or, alternatively, to stay enforcement of the administrative order. Judge Wilmoth denied the requested relief. 4 Syl. Pt. 4, in part, State ex rel. Hoover v. Berger, 199 W. Va. 12, 483 S.E.2d 12 (1996).

2 . . . the third factor, the existence of clear error as a matter of law, should be given substantial weight.”5

In consideration of these factors—and the existence of clear error as a matter of law in particular—the writ sought by DHS here should issue. Put simply, Judge Wilmoth has identified no legal authority that would support this unusual use of an administrative order, and we find none. To begin, we note that the administrative order sounds in mandamus, as Judge Wilmoth directs DHS to keep the Children’s Home open to meet its statutory obligations regarding the care of juveniles. “Mandamus lies to require the discharge by a public officer of a nondiscretionary duty.”6 It “will issue where the undisputed facts show that petitioner has clear legal right to the performance of the act demanded, and a corresponding duty rests upon respondent to perform that duty; and that there is no other adequate remedy open to petitioner.”7 Setting aside the fact that no person or entity requested judicial action, and that Judge Wilmoth acted unilaterally, mandamus does not lie here because DHS has no nondiscretionary duty to keep the Children’s Home open. To be sure, DHS has statutory authority regarding the care and custody of juveniles. But in the absence of any abdication of this responsibility, which is not demonstrated by DHS’s decision to close the Children’s Home,8 mandamus “is never employed to prescribe in what manner [a governmental agency] shall act.”9 So to the extent the administrative order functions in the place of a writ of mandamus, it is not proper.

More problematically, this recognition of DHS’s authority compels the conclusion that Judge Wilmoth exceeded his own.

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Bluebook (online)
SER WV Department of Human Services v. The Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ser-wv-department-of-human-services-v-the-honorable-david-h-wilmoth-wva-2025.