West Virginia Case Commentaries

State v. Rue: No plain‑error relief for felony‑murder instructional complaint under a general first-degree murder verdict; reaffirmation of trial courts’ discretion to give initial‑aggressor self‑defense instructions

Date: Sep 17, 2025

State v. Rue: No plain‑error relief for felony‑murder instructional complaint under a general first-degree murder verdict; reaffirmation of trial courts’ discretion to give initial‑aggressor...

Roberts Reaffirms Objective Pretext Doctrine and Recorded-Consent Vehicle Searches in West Virginia

Date: Sep 17, 2025

Roberts Reaffirms Objective Pretext Doctrine and Recorded-Consent Vehicle Searches in West Virginia Introduction In State of West Virginia v. Steven Verrell Roberts, No. 23-422 (W. Va. Sept. 16,...

State v. Austin: Voluntary Intoxication and Diminished Capacity Limits, Narrow “Opening the Door,” and What Counts as an Overt Act for Attempted First-Degree Murder

Date: Sep 17, 2025

State v. Austin: Voluntary Intoxication and Diminished Capacity Limits, Narrow “Opening the Door,” and What Counts as an Overt Act for Attempted First-Degree Murder Introduction In State of West...

No “Child’s-Choice” Visitation Without Findings and a Plan: In re H.C. Reinforces Child-Centered Continued-Association Standards in Guardianship Cases

Date: Sep 17, 2025

No “Child’s-Choice” Visitation Without Findings and a Plan: In re H.C. Reinforces Child-Centered Continued-Association Standards in Guardianship Cases Introduction In a memorandum decision issued...

Counsel’s Verification Suffices to Satisfy Rule 32(c)(3)(A); Unraised PSI Objections Are Waived — State v. Layton

Date: Sep 11, 2025

Counsel’s Verification Suffices to Satisfy Rule 32(c)(3)(A); Unraised PSI Objections Are Waived — State v. Layton Introduction In State of West Virginia v. Thomas Layton, No. 24-685 (Sept. 10, 2025),...

Requesting FMLA Paperwork Is Not Protected Activity: West Virginia Supreme Court clarifies Harless retaliation and reinforces WVHRA prima facie and pretext standards

Date: Sep 11, 2025

Requesting FMLA Paperwork Is Not Protected Activity: West Virginia Supreme Court clarifies Harless retaliation and reinforces WVHRA prima facie and pretext standards Introduction In Cindy Linger-Long...

Spears v. Frame: Habeas Orders Must Contain Petitioner-Specific Findings; Incorporating a Co‑Defendant’s Findings Is Insufficient for Meaningful Appellate Review

Date: Sep 11, 2025

Spears v. Frame: Habeas Orders Must Contain Petitioner-Specific Findings; Incorporating a Co‑Defendant’s Findings Is Insufficient for Meaningful Appellate Review Court: Supreme Court of Appeals of...

Rule 35(b) in West Virginia: No Entitlement to Appointed Experts and Concise Orders Can Suffice — State v. Jeffery (W. Va. Sept. 10, 2025)

Date: Sep 11, 2025

Rule 35(b) in West Virginia: No Entitlement to Appointed Experts and Concise Orders Can Suffice — State v. Jeffery Introduction In State of West Virginia v. Joey Keith Jeffery, No. 23-538 (Kanawha...

“Good Cause” Means More Than Docket Delay; Written Motion Required for Improvement Periods: Commentary on In re J.S.-1 and J.S.-2 (W. Va. Sept. 10, 2025)

Date: Sep 11, 2025

“Good Cause” Means More Than Docket Delay; Written Motion Required for Improvement Periods: Commentary on In re J.S.-1 and J.S.-2 (W. Va. Sept. 10, 2025) Introduction In re J.S.-1 and J.S.-2 is a...

Nonparticipation Precludes Improvement Period: West Virginia Supreme Court Reaffirms Denial of Improvement Period and Termination Where Parent Fails to Engage, Despite Mental Health Claims

Date: Sep 11, 2025

Nonparticipation Precludes Improvement Period: West Virginia Supreme Court Reaffirms Denial of Improvement Period and Termination Where Parent Fails to Engage, Despite Mental Health Claims...

No Improvement Without Acknowledgment: West Virginia Affirms Denial of Improvement Period and Child-Specific Dispositions in Domestic-Violence-Based Abuse and Neglect

Date: Sep 11, 2025

No Improvement Without Acknowledgment: West Virginia Affirms Denial of Improvement Period and Child-Specific Dispositions in Domestic-Violence-Based Abuse and Neglect Case: In re T.B., T.D., J.C.-1,...

Counsel’s Representation Suffices to Verify PSI Review Under Rule 32(c)(3)(A); Failure to Object Waives Challenge (State v. Layton)

Date: Sep 11, 2025

Counsel’s Representation Suffices to Verify PSI Review Under Rule 32(c)(3)(A); Failure to Object Waives Challenge Introduction In State of West Virginia v. Thomas Layton (No. 24-685), the Supreme...

Reaffirming Rule 35(a)’s Narrow Reach and the Definite Sentencing Scheme for Voluntary Manslaughter in West Virginia

Date: Sep 11, 2025

Reaffirming Rule 35(a)’s Narrow Reach and the Definite Sentencing Scheme for Voluntary Manslaughter in West Virginia Introduction This commentary examines the Supreme Court of Appeals of West...

Failure to Enter Court-Ordered Substance Abuse Treatment Supports “No Reasonable Likelihood” Finding and Termination of Parental Rights

Date: Sep 11, 2025

Failure to Enter Court-Ordered Substance Abuse Treatment Supports “No Reasonable Likelihood” Finding and Termination of Parental Rights Introduction In re S.H., No. 24-555 (W. Va. Sept. 10, 2025), is...

Belated, Insincere Acknowledgment Is Insufficient for an Improvement Period; Termination May Proceed Even When the Other Parent Is Fit — In re S.B., H.B., D.B., and N.B.

Date: Sep 11, 2025

Belated, Insincere Acknowledgment Is Insufficient for an Improvement Period; Termination May Proceed Even When the Other Parent Is Fit — In re S.B., H.B., D.B., and N.B. Introduction This memorandum...

In re H.C.: No Automatic Post‑Guardianship Visitation—Parental Rehabilitation Alone Is Insufficient Absent a Strong Bond and Best‑Interests Showing

Date: Sep 11, 2025

In re H.C.: No Automatic Post‑Guardianship Visitation—Parental Rehabilitation Alone Is Insufficient Absent a Strong Bond and Best‑Interests Showing Introduction This memorandum decision from the...

In re F.S.: Compelled Treatment, Aggravated Circumstances, and the Written-Motion Requirement for Improvement Periods

Date: Sep 11, 2025

In re F.S.: Compelled Treatment, Aggravated Circumstances, and the Written-Motion Requirement for Improvement Periods Introduction In this memorandum decision, the Supreme Court of Appeals of West...

Reaffirming That Noncompliance With DHS Services Precludes an Improvement Period and Supports Termination: In re E.Y. and G.S.

Date: Sep 11, 2025

Reaffirming That Noncompliance With DHS Services Precludes an Improvement Period and Supports Termination: In re E.Y. and G.S. Introduction In In re E.Y. and G.S., No. 24-358 (W. Va. Sept. 10, 2025)...

Child Disclosures and Behavioral Corroboration Can Meet the Clear-and-Convincing Standard Without Physical Evidence; Rule 19(b) Permits Reopened Adjudications on Amended Allegations

Date: Sep 11, 2025

Child Disclosures and Behavioral Corroboration Can Meet the Clear-and-Convincing Standard Without Physical Evidence; Rule 19(b) Permits Reopened Adjudications on Amended Allegations Introduction In...

Case-Specific Findings Required in Habeas Orders; Incorporation from a Co-Defendant’s Case Is Insufficient When the Evidence Materially Differs — Spears v. Frame (W. Va. 2025)

Date: Sep 11, 2025

Case-Specific Findings Required in Habeas Orders; Incorporation from a Co-Defendant’s Case Is Insufficient When the Evidence Materially Differs — Spears v. Frame (W. Va. 2025) Introduction In William...