West Virginia Case Commentaries

Rule 26(a) Stipulations as Sufficient Basis for Adjudication When Children Are in the Parent’s Custody

Date: Oct 16, 2025

Rule 26(a) Stipulations as Sufficient Basis for Adjudication When Children Are in the Parent’s Custody Case: In re K.M. and L.M., No. 24-679 (W. Va. Oct. 14, 2025) — Supreme Court of Appeals of West...

Relapse and Non‑Engagement After Extended Improvement Periods Satisfy “No Reasonable Likelihood” Standard Under W. Va. Code § 49‑4‑604: Commentary on In re K.M. and L.M. (W. Va. 2025)

Date: Oct 16, 2025

Relapse and Non‑Engagement After Extended Improvement Periods Satisfy “No Reasonable Likelihood” Standard Under W. Va. Code § 49‑4‑604: Commentary on In re K.M. and L.M. (W. Va. 2025) Introduction In...

Relapse and Non‑Participation During Improvement Periods Establish “No Reasonable Likelihood” and Permit Termination Without Less Restrictive Alternatives: Commentary on In re K.M. and L.M.

Date: Oct 15, 2025

Relapse and Non‑Participation During Improvement Periods Establish “No Reasonable Likelihood” and Permit Termination Without Less Restrictive Alternatives: Commentary on In re K.M. and L.M....

Rule 26(a) Stipulations Alone Can Support Adjudication When Children Are in the Parent’s Custody: In re K.M. and L.M. (W. Va. 2025)

Date: Oct 15, 2025

Rule 26(a) Stipulations Alone Can Support Adjudication When Children Are in the Parent’s Custody Case: In re K.M. and L.M., No. 24-679 (Supreme Court of Appeals of West Virginia, Oct. 14, 2025)...

Noncompliance and Open‑Ended Incarceration: Termination Without Less Restrictive Alternatives and No Post‑Dispositional Improvement Period

Date: Oct 1, 2025

Noncompliance and Open‑Ended Incarceration: Termination Without Less Restrictive Alternatives and No Post‑Dispositional Improvement Period Case: In re A.F. and H.J., No. 24-574 Court: Supreme Court...

Consent to Guardianship Is Not a Safe Harbor: West Virginia Affirms Termination Where No Reasonable Likelihood of Correction Exists

Date: Oct 1, 2025

Consent to Guardianship Is Not a Safe Harbor: West Virginia Affirms Termination Where No Reasonable Likelihood of Correction Exists Case: In re A.A., K.A., and A.R., No. 24-474 (W. Va. Sept. 30,...

In re G.J.: Refusal to Engage in Services Justifies Termination Without Less Restrictive Alternatives and Supports Denial of Post‑Termination Visitation

Date: Oct 1, 2025

In re G.J.: Refusal to Engage in Services Justifies Termination Without Less Restrictive Alternatives and Supports Denial of Post‑Termination Visitation Introduction In a memorandum decision dated...

In re G.A.: West Virginia High Court Reaffirms Written-Motion Prerequisite for Improvement Periods and Clarifies That Less Restrictive Alternatives Are Not Required When Statutory Termination Criteria Are Met

Date: Oct 1, 2025

In re G.A.: Reaffirming the Written-Motion Requirement for Improvement Periods and the Permissibility of Termination Without Less Restrictive Alternatives Introduction In a memorandum decision issued...

Express Findings and Maximization Required to Deviate from West Virginia’s Statutory 50/50 Custody Presumption

Date: Oct 1, 2025

Express Findings and Maximization Required to Deviate from West Virginia’s Statutory 50/50 Custody Presumption Introduction In In re R.L., No. 24-395 (W. Va. Sept. 30, 2025), the Supreme Court of...

Reaffirming Denial of Improvement Periods and Termination Where Parent Fails to Engage: West Virginia High Court’s Memorandum Decision in In re J.H., J.M., T.K., and R.K.

Date: Oct 1, 2025

Reaffirming Denial of Improvement Periods and Termination Where Parent Fails to Engage: West Virginia High Court’s Memorandum Decision in In re J.H., J.M., T.K., and R.K. Introduction This commentary...

Reaffirming West Virginia’s 50-50 Custody Presumption: Trial Courts Must Apply § 48-9-102a, Analyze § 48-9-209(f) Factors, Enter Written Findings, and Maximize Parenting Time

Date: Oct 1, 2025

Reaffirming West Virginia’s 50-50 Custody Presumption: Trial Courts Must Apply § 48-9-102a, Analyze § 48-9-209(f) Factors, Enter Written Findings, and Maximize Parenting Time Case: In re R.L., No....

Reaffirming the Rule 8(a) Presumption and Tightening Limits on Child Confrontation, Discovery, and Sexual-History Evidence in Abuse-and-Neglect Adjudications

Date: Oct 1, 2025

Reaffirming the Rule 8(a) Presumption and Tightening Limits on Child Confrontation, Discovery, and Sexual-History Evidence in Abuse-and-Neglect Adjudications Introduction In re L.H.-1, B.H., L.H.-2,...

Improvement Period May Be Denied When a Parent’s Promise to a Critical No‑Contact Condition Lacks Credibility, Even Amid Services Compliance

Date: Oct 1, 2025

Improvement Period May Be Denied When a Parent’s Promise to a Critical No‑Contact Condition Lacks Credibility, Even Amid Services Compliance Introduction In In re I.R. and E.B., No. 24-496 (W. Va....

Reasonable Efforts May Be Satisfied by Prior and Ongoing Services; Trial Court Credibility Findings Govern Post‑Termination Visitation (In re D.G. and L.G.)

Date: Oct 1, 2025

Reasonable Efforts May Be Satisfied by Prior and Ongoing Services; Trial Court Credibility Findings Govern Post‑Termination Visitation Commentary on In re D.G. and L.G., No. 24-595 (W. Va. Sept. 30,...

Consent to Legal Guardianship Does Not Limit Court’s Authority to Terminate Parental Rights When No Reasonable Likelihood of Correction Exists

Date: Oct 1, 2025

Consent to Legal Guardianship Does Not Limit Court’s Authority to Terminate Parental Rights When No Reasonable Likelihood of Correction Exists Introduction In a memorandum decision issued on...

Reasonable Efforts Clarified: Prior-Case Services and Futility Can Satisfy DHS’s Reunification Duty in Recidivist Neglect Cases

Date: Oct 1, 2025

Reasonable Efforts Clarified: Prior-Case Services and Futility Can Satisfy DHS’s Reunification Duty in Recidivist Neglect Cases Introduction In re D.G. and L.G., No. 24-620 (W. Va. Sept. 30, 2025),...

In re B.S.: The 15/22-Month Permanency Cap Meaningfully Limits Improvement-Period Extensions; Near-Completion of Treatment Is Not a “Compelling Circumstance”

Date: Oct 1, 2025

In re B.S.: The 15/22-Month Permanency Cap Meaningfully Limits Improvement-Period Extensions; Near-Completion of Treatment Is Not a “Compelling Circumstance” Introduction In this memorandum decision,...

In re B.N.: Delineated, Best‑Interest Visitation for Relative Caregivers Without a Grandparent Visitation Act Motion—and Strict Standing Limits for Non‑Intervenor Grandparents

Date: Oct 1, 2025

In re B.N.: Delineated, Best‑Interest Visitation for Relative Caregivers Without a Grandparent Visitation Act Motion—and Strict Standing Limits for Non‑Intervenor Grandparents Introduction The...

Temporary Guardianship Does Not Defeat Abuse-and-Neglect Jurisdiction; Voluntary Relinquishment Bars Case-Plan Attacks — Commentary on In re A.F. and K.F. (W. Va. Sept. 30, 2025)

Date: Oct 1, 2025

Temporary Guardianship Does Not Defeat Abuse-and-Neglect Jurisdiction; Voluntary Relinquishment Bars Case-Plan Attacks — Commentary on In re A.F. and K.F. (W. Va. Sept. 30, 2025) Introduction This...

Termination Without Less Restrictive Alternatives and a Rigorous “Substantial Change” Threshold for Post‑Dispositional Improvement Periods: Commentary on In re A.F. and H.J.

Date: Oct 1, 2025

Termination Without Less Restrictive Alternatives and a Rigorous “Substantial Change” Threshold for Post‑Dispositional Improvement Periods: Commentary on In re A.F. and H.J. Introduction This...