West Virginia Case Commentaries

“Not a Critical Stage”: Supreme Court of West Virginia Re-Affirms Strict Frazier Test and Denies Right to Counsel or Hearing on Post-Sentence Motions to Withdraw Guilty Pleas

Date: Aug 1, 2025

“Not a Critical Stage”: Supreme Court of West Virginia Re-Affirms Strict Frazier Test and Denies Right to Counsel or Hearing on Post-Sentence Motions to Withdraw Guilty Pleas 1. Introduction In State...

Inherent Violence & Proportionality in Recidivist Life Sentences: A Commentary on State v. Cottingham (W. Va. 2025)

Date: Aug 1, 2025

Inherent Violence & Proportionality in Recidivist Life Sentences: A Comprehensive Commentary on State of West Virginia v. Antonio Devon Cottingham (2025) 1. Introduction In State v. Cottingham, the...

State v. Harrison: No Pre-Habeas Right to Grand-Jury Transcripts After a Guilty Plea

Date: Aug 1, 2025

State v. Harrison: No Pre-Habeas Right to Grand-Jury Transcripts After a Guilty Plea Introduction State of West Virginia v. Joshua James Harrison (Supreme Court of Appeals of West Virginia, 30 July...

Circumstantial Sufficiency: Supreme Court of West Virginia Clarifies Standard for “Concealment of a Deceased Human Body” – Commentary on State v. Anthony Yester (2025)

Date: Aug 1, 2025

Circumstantial Sufficiency: Supreme Court of West Virginia Clarifies Standard for “Concealment of a Deceased Human Body” – Commentary on State of West Virginia v. Anthony Yester Introduction The...

State v. Robinson: Re-Affirming the Limited Scope of Appellate Review over Statutorily-Bound Sentences and Jury Verdicts in West Virginia

Date: Aug 1, 2025

State v. Robinson: Re-Affirming the Limited Scope of Appellate Review over Statutorily-Bound Sentences and Jury Verdicts in West Virginia 1. Introduction In State of West Virginia v. Marques Robinson...

State v. Grant S.: Testimonial Evidence Alone Can Sustain Revocation of Home Incarceration in West Virginia

Date: Aug 1, 2025

State v. Grant S.: Testimonial Evidence Alone Can Sustain Revocation of Home Incarceration in West Virginia Introduction In State of West Virginia v. Grant S. (Supreme Court of Appeals of West...

“The Voluntary-Acceptance Rule”: Supreme Court of West Virginia Clarifies When Failure to File Financial Disclosure Will Not Upset a Divorce Settlement (Anne Y. v. Daniel Y., 2025)

Date: Jul 3, 2025

“The Voluntary-Acceptance Rule” Supreme Court of West Virginia Clarifies When Failure to File Financial Disclosure Will Not Upset a Divorce Settlement Introduction Anne Y. v. Daniel Y., decided on 27...

In re A.T., B.T., and N.T.: Harmless-Error Review of Improperly Dismissing Parents Who Have Retained Rights from Post-Disposition Permanency Proceedings

Date: Jul 3, 2025

In re A.T., B.T., and N.T.: The Supreme Court of West Virginia Clarifies that Erroneously Excluding Parents (Whose Rights Are Intact) from Abuse-and-Neglect Permanency Hearings May Constitute...

Gilhuys v. Hardy County 911 Center: When Lack of Comparators Justifies Summary Judgment Despite Ongoing Discovery in WVHRA Actions

Date: Jul 3, 2025

Gilhuys v. Hardy County 911 Center: When Lack of Comparators Justifies Summary Judgment Despite Ongoing Discovery in WVHRA Actions Introduction In Gilhuys v. Hardy County 911 Center, the Supreme...

“In re A.H.” – Reaffirming the Constitutional Presumption of Fit Parental Custody and Defining the Bounds of Non-Parent Intervention in West Virginia

Date: Jul 3, 2025

“In re A.H.” – Reaffirming the Constitutional Presumption of Fit Parental Custody and Defining the Bounds of Non-Parent Intervention in West Virginia 1. Introduction In In re A.H., No. 23-596 (W. Va....

Reinstatement of the Parental-Fitness Presumption After Rehabilitation – Commentary on In re A.H. (W. Va. 2025)

Date: Jul 3, 2025

Reinstatement of the Parental-Fitness Presumption After Rehabilitation – Commentary on In re A.H. (Supreme Court of Appeals of West Virginia, 2025) 1. Introduction In re A.H. presented the Supreme...

“When Protection Outweighs Rehabilitation” – Supreme Court of West Virginia Affirms Immediate Termination of Parental Rights Where the Abusing Parent Persistently Maintains a Violent Relationship and Rejects Offered Services

Date: Jul 3, 2025

“When Protection Outweighs Rehabilitation” – Supreme Court of West Virginia Affirms Immediate Termination of Parental Rights Where the Abusing Parent Persistently Maintains a Violent Relationship and...

From Presumption to Discretion: Clarifying the Standard for Post-Dispositional Improvement Periods in West Virginia – A Commentary on In re D.S. (2025)

Date: Jul 3, 2025

From Presumption to Discretion: Clarifying the Standard for Post-Dispositional Improvement Periods in West Virginia – A Commentary on In re D.S. (Supreme Court of Appeals, 2025) Introduction In re...

“Denial, Continued Association, and the Futility Test” – Supreme Court of West Virginia Clarifies When Improvement Periods May Be Refused in Abuse-and-Neglect Cases

Date: Jul 3, 2025

“Denial, Continued Association, and the Futility Test” – Supreme Court of West Virginia Clarifies When Improvement Periods May Be Refused in Abuse-and-Neglect Cases I. Introduction In In re E.H.,...

“Reasonable, Not Specialized”: West Virginia Affirms that Child-Welfare Agencies Need Not Provide Specialized ADA Training When Accommodating Parents with Autism

Date: Jul 3, 2025

“Reasonable, Not Specialized”: West Virginia Affirms that Child-Welfare Agencies Need Not Provide Specialized ADA Training When Accommodating Parents with Autism Introduction In In re E.K., S.C., and...

“Re-evaluating Post-Termination Contact: The West Virginia Supreme Court Declares Specific Findings Mandatory Before Denying Visitation”

Date: Jul 3, 2025

“Re-evaluating Post-Termination Contact: The West Virginia Supreme Court Declares Specific Findings Mandatory Before Denying Visitation” Introduction In In re J.N.-1 (2025), the Supreme Court of...

“Denial as Non-Compliance” – West Virginia High Court Confirms that a Parent’s Failure to Acknowledge Abuse Justifies Early Termination of Improvement Periods and Parental Rights

Date: Jul 3, 2025

“Denial as Non-Compliance” – West Virginia Supreme Court Clarifies that Failure to Acknowledge Abuse Constitutes Grounds for Terminating Both Improvement Periods and Parental Rights Introduction The...

The “Equal-Probability” Threshold: West Virginia Supreme Court Clarifies the Clear-and-Convincing Standard in Child-Sexual-Abuse Adjudications

Date: Jul 3, 2025

The “Equal-Probability” Threshold: West Virginia Supreme Court Clarifies the Clear-and-Convincing Standard in Child-Sexual-Abuse Adjudications Introduction On 26 June 2025 the Supreme Court of...

“Significant-Connection Jurisdiction” and Incarceration-Based Neglect: A Comprehensive Commentary on In re L.H. (W. Va. 2025)

Date: Jul 3, 2025

“Significant-Connection Jurisdiction” and Incarceration-Based Neglect: Commentary on the Supreme Court of Appeals of West Virginia’s Decision in In re L.H. (2025) 1. Introduction In re L.H., No....

“In re L.M.”: The West Virginia Supreme Court Confirms that Parental Rights May Be Terminated Without Lesser Alternatives When the Parent Fails to Acknowledge Abuse or Comply with an Improvement Period

Date: Jul 3, 2025

In re L.M.: The West Virginia Supreme Court Confirms that Parental Rights May Be Terminated Without Lesser Alternatives When the Parent Fails to Acknowledge Abuse or Comply with an Improvement Period...