Credible Child Sexual Abuse Disclosures, Parental Non‑Acknowledgment, and Termination of Parental Rights: Commentary on In re W.W. and L.W.

1. Introduction

The Supreme Court of Appeals of West Virginia’s memorandum decision in In re W.W. and L.W., No. 24-559 (Nov. 4, 2025), affirms a circuit court order terminating a mother’s parental rights based on sexual abuse of her children and her continued denial of that abuse. Although issued as a memorandum decision under Rule 21 of the West Virginia Rules of Appellate Procedure, the opinion meaningfully reinforces several important doctrines in West Virginia abuse and neglect law:

Sexual abuse may be proven solely by a child victim’s testimony, even if uncorroborated, where the circuit court finds that testimony credible.
A parent’s refusal to acknowledge sexual abuse is a central, sometimes dispositive, factor in denying an improvement period as “futile.”
Termination of one parent’s rights remains proper—even where the children have permanency with the other, nonabusing parent—when statutory conditions for termination are met.

The case involves allegations that the petitioner mother (“J.W.”) sexually abused her son (“W.W.”) and compelled him to sexually touch his younger sister (“L.W.”). The Department of Human Services (DHS) initially filed a petition in 2020 against the father concerning domestic violence; the mother was added later, first on unrelated felony charges and then, in a second amended petition, on specific allegations of sexual abuse.

The core issues on appeal were:

Whether the circuit court erred in adjudicating the mother as an “abusing parent” based largely on W.W.’s disclosures.
Whether the court abused its discretion in denying the mother a post‑adjudicatory improvement period.
Whether termination of the mother’s parental rights was improper given the availability of less restrictive alternatives and the children’s permanency with their father.

The Supreme Court affirmed on all points, providing a clear restatement of the interplay between evidentiary sufficiency (especially in child sexual abuse cases), the statutory framework governing improvement periods, and the broad authority to terminate one parent’s rights while preserving permanency with another.

2. Summary of the Opinion

The DHS originally initiated proceedings due to domestic violence by the father. Two years later, the mother was added to the case after an indictment on felony charges (subsequently withdrawn from the abuse/neglect petition by agreement with DHS). Critical allegations then emerged in a second amended petition: that the mother had sexually abused W.W. and forced him to engage in sexual acts with L.W.

W.W., then ten, disclosed to the guardian ad litem and in a forensic interview that:

The mother put her mouth on his “bad spot.”
She made him touch L.W.’s “bad spot” between her legs.
The abuse began when he was about five and continued until he was removed from the mother’s custody.

In an in camera interview with the circuit court in December 2023, W.W. repeated and elaborated on these disclosures. He admitted inappropriate touching of L.W., his stepsister, and a cousin after removal, explaining he believed such behavior was “normal.” He also stated he did not want to live with or see his mother and denied being coached.

At the February 2024 adjudicatory hearing:

The circuit court took judicial notice of W.W.’s forensic interview and his in camera interview.
W.W.’s therapist, qualified as an expert in trauma-based therapy, testified to disclosures mirroring those given elsewhere.
A CPS worker testified that W.W.’s descriptions of sexual abuse were consistent across all settings and that she had no reason to believe he was lying.
The mother denied any sexual abuse, conceded W.W. was generally an “honest kid,” and blamed the father for allegedly coercing him to lie.

The circuit court found W.W.’s disclosures “clear, consistent[,] and credible” and “not the result of force, threats[,] or coercion,” while finding the mother’s denial self-serving and not credible. It adjudicated the mother an abusing parent and both children as abused.

At the July 2024 dispositional hearing, the mother sought a post‑adjudicatory improvement period. She:

Asked for an improvement period to work towards reunification.
Expressly denied needing services to address sexual abuse, stating she had taken no steps to correct abuse because she did not commit any.

Stated she would do “whatever” was required but without acknowledging any underlying sexual abuse.

A CPS worker recommended termination, citing the continued denial of abuse. The circuit court:

Denied the improvement period because the mother continued to deny the “basic allegations” of sexual abuse.
Found there was no reasonable likelihood the conditions of abuse could be substantially corrected in the near future.
Found termination necessary for the children’s welfare and ordered termination of the mother’s parental rights; the father retained custody, and permanency was to remain with him.

On appeal, the mother argued:

The evidence of sexual abuse was insufficient and based only on W.W.’s “odd and uncorroborated” statements.
She had shown she was likely to fully participate in an improvement period, and denial was an abuse of discretion.
Termination was excessively harsh because less restrictive dispositions were available, particularly given the children’s permanency with the father.
(Separately) the circuit court mishandled allegations in an earlier amended petition tied to her criminal charges.

The Supreme Court:

Applied a clear-error standard to factual findings and de novo review to legal conclusions (In re Cecil T.).
Held that under In re K.P., sexual abuse can be proven solely by the child victim’s testimony, even if uncorroborated; W.W.’s consistent disclosures, plus professional testimony, easily satisfied that standard.
Refused to reweigh credibility, emphasizing deference to the circuit court’s witness assessments (In re D.S.; Michael D.C. v. Wanda L.C.).
Affirmed denial of an improvement period, relying on the doctrine that failure to acknowledge abuse makes the problem “untreatable” and any improvement period “an exercise in futility” (In re Timber M., quoting In re Charity H.; see also In re Tonjia M.).
Upheld termination under West Virginia Code § 49-4-604(c)(6), citing In re Kristen Y. and In re R.J.M. for the rule that termination may occur without using intervening less restrictive alternatives once there is no reasonable likelihood of correction.
Reaffirmed In re Emily that § 49-4-604 permits termination of one parent’s rights while leaving the nonabusing parent’s rights intact.
Declined to address the complaint about the earlier amended petition because the circuit court had dismissed it.

The circuit court’s order terminating the mother’s parental rights was affirmed.

3. Detailed Analysis

3.1 Procedural Background and Factual Context

The trajectory of this case illustrates the layered nature of abuse and neglect proceedings:

Initial Petition (2020): DHS filed an abuse and neglect petition against the father over domestic violence. The mother was not initially a respondent.
Amended Petition (around 2022): The mother was added after indictment on unspecified felony charges. These allegations were later withdrawn from the abuse/neglect case by agreement with DHS and ultimately dismissed by the circuit court, which is why the Supreme Court declined to consider any alleged error tied to them.
Second Amended Petition (2023): DHS then filed a second amended petition specifically alleging that the mother:
- Sexually abused W.W. (oral contact with his genitals).
- Forced W.W. to perform sexual acts on L.W. (touching her between the legs).
Child Disclosures:
- To the guardian ad litem (initial disclosure).
- In a forensic interview (July 21, 2023).
- In camera to the circuit court judge (December 2023).
- To his trauma therapist and to the CPS worker.
W.W. consistently described the abuse, dating it back to when he was about five and continuing until removal; he also candidly admitted his own inappropriate behavior after removal.
Adjudicatory Hearing (February 2024): The circuit court:
- Took judicial notice of the forensic and in camera interviews.
- Heard expert testimony from W.W.’s trauma therapist and fact testimony from a CPS worker and others.
- Heard the mother’s denial, including her theory that the father coerced W.W. to lie.
- Explicitly found W.W. credible and the mother not credible, and adjudicated the mother an abusing parent.
Dispositional Hearing (July 2024): The mother sought an improvement period but continued to deny any sexual abuse, explicitly stating she had taken no steps to address abuse because she did not commit it. The court denied an improvement period and terminated her parental rights, while the children remained in the father’s care.

This sequence is important because it shows the classic two-stage structure of abuse and neglect proceedings in West Virginia—adjudication (deciding whether abuse/neglect occurred) and disposition (deciding what happens to parental rights once abuse/neglect is found). The Supreme Court’s reasoning tracks these stages closely.

3.2 Standards of Review and Burdens of Proof

The Court begins its legal analysis by reiterating the standard of review:

Syllabus Point 1, In re Cecil T., 228 W. Va. 89, 717 S.E.2d 873 (2011): On appeal from a final order in an abuse and neglect proceeding, the circuit court’s findings of fact are reviewed under a clearly erroneous standard, while conclusions of law are reviewed de novo.

Applied here:

The mother could only succeed on the adjudicatory challenge by showing the circuit court’s factual findings (e.g., that abuse occurred, that W.W. was credible) were clearly erroneous.
Questions about interpretation of § 49-4-610 (improvement periods) or § 49-4-604 (dispositional alternatives and termination) were reviewed de novo, but those statutes are well settled and were not seriously in dispute.

The relevant burdens and standards of proof are:

Adjudication (abuse/neglect): DHS must prove abuse or neglect by clear and convincing evidence. The mother argued that this standard was not met because W.W.’s statements were “odd” and “uncorroborated.”
Improvement period: Under § 49-4-610(2), the parent seeking a post‑adjudicatory improvement period has the burden to demonstrate, by clear and convincing evidence, that they are likely to fully participate in the improvement period.
Termination: For disposition under § 49-4-604(c)(6), the circuit court must find (1) no reasonable likelihood that the conditions of abuse/neglect can be substantially corrected in the near future and (2) that termination is necessary for the child’s welfare.

The opinion shows how each of these burdens ultimately cut against the mother:

On adjudication, In re K.P. eliminated the need for corroboration of a child victim’s testimony.
On the improvement period, the mother failed to show any realistic likelihood of participation in treatment for sexual abuse because she never accepted its existence.
On termination, her continued denial led directly to the conclusion that conditions could not be corrected, justifying termination without lesser alternatives.

3.3 Adjudication Based on Child Sexual Abuse Disclosures

3.3.1 The Mother’s Challenge

The mother’s primary adjudicatory argument was that DHS had not proven sexual abuse by clear and convincing evidence because:

The only substantial evidence came from W.W.’s statements.
She characterized those statements as “somewhat odd and uncorroborated,” “inconsistent,” “not based in fact,” and “bizarre.”

She further claimed that the father coerced W.W. into fabricating allegations.

3.3.2 Reliance on In re K.P.: Child’s Testimony Alone Can Suffice

The Supreme Court directly invoked its prior ruling in In re K.P., 235 W. Va. 221, 772 S.E.2d 914 (2015), stating:

“Sexual abuse may be proven solely with the victim’s testimony, even if that testimony is uncorroborated.”
– In re K.P., 235 W. Va. at 230, 772 S.E.2d at 923.

This principle is pivotal. It squarely defeats the mother’s premise that the absence of corroboration—or the presence of only the child’s testimony—renders the evidence insufficient. Legally:

There is no requirement for physical evidence, eyewitnesses, or expert confirmation of abuse beyond what the victim says.
The critical question becomes not whether the child’s testimony is corroborated, but whether the trier of fact finds the child credible by the clear and convincing standard.

In W.W. and L.W., W.W.’s disclosures were in fact stronger than those in many uncorroborated-testimony cases because:

He repeated them in multiple contexts (guardian, forensic interview, therapist, CPS worker, in camera interview) with consistency.
The therapist (qualified as an expert in trauma-based therapy) confirmed the disclosures as consistent and credible.
The CPS worker testified that W.W.’s descriptions did not vary and that she had no reason to doubt him.

Even though the transcript of the forensic interview was not in the appellate appendix, the circuit court took judicial notice of it, and the Supreme Court accepted the circuit court’s reliance on that interview and the in camera testimony as part of the factual record.

3.3.3 Deference to Credibility Determinations

The Supreme Court emphasized a second, related principle: appellate courts do not reweigh evidence or reassess witness credibility. It cited:

In re D.S., 251 W. Va. 466, 914 S.E.2d 701, 707 (2025), reaffirming that the Court does “not reweigh the evidence or make credibility determinations.”
Michael D.C. v. Wanda L.C., 201 W. Va. 381, 388, 497 S.E.2d 531, 538 (1997), noting that the trier of fact is “uniquely situated” to evaluate credibility and appellate courts will not “second guess” such determinations.

These cases collectively support this doctrinal hierarchy:

The circuit court, as fact-finder, hears and observes witnesses, including children, in real time.
If the circuit court finds a child’s disclosures “clear, consistent, and credible,” that finding is reviewed for clear error only.
Absent some compelling reason (e.g., internal contradiction, impossibility, or serious procedural flaw), the Supreme Court will not substitute its own judgment for the circuit court’s on credibility.

In the present case, the Supreme Court expressly deferred to:

The circuit court’s finding that W.W.’s disclosures were credible and uncoerced.
The court’s finding that the mother’s denial was “self-serving and not credible.”

Thus, even had W.W.’s testimony been truly “uncorroborated” in the strictest sense, In re K.P. and the deference owed to the trial court’s credibility assessments would suffice to uphold the adjudication. The presence of consistent professional testimony only fortified the trial court’s conclusions.

3.4 Denial of Post‑Adjudicatory Improvement Period

3.4.1 Statutory Framework: § 49‑4‑610(2)

Under West Virginia Code § 49‑4‑610(2), a circuit court may grant a post‑adjudicatory improvement period if:

The parent “demonstrates, by clear and convincing evidence, that [she] is likely to fully participate in the improvement period.”

Key features of this standard:

The burden is on the parent, not DHS.
The parent must show both willingness and realistic ability to engage in remedial services that address the actual conditions of abuse or neglect.

3.4.2 Court’s Discretion and the Concept of Futility

The Supreme Court emphasized that improvement periods are discretionary and may be denied where little or no improvement is likely, citing:

In re Tonjia M., 212 W. Va. 443, 448, 573 S.E.2d 354, 359 (2002): circuit courts may deny an improvement period when “no improvement is likely.”

More significantly, the Court relied on the doctrine articulated in In re Timber M., 231 W. Va. 44, 743 S.E.2d 352 (2013), which in turn quoted In re Charity H., 215 W. Va. 208, 599 S.E.2d 631 (2004):

“[T]o remedy the abuse and/or neglect problem, the problem must first be acknowledged. Failure to acknowledge the existence of the problem, i.e., the truth of the basic allegation pertaining to the alleged abuse and neglect or the perpetrator of said abuse and neglect, results in making the problem untreatable and in making an improvement period an exercise in futility at the child’s expense.”
– In re Timber M., 231 W. Va. at 55, 743 S.E.2d at 363 (quoting In re Charity H.)

This language has become a cornerstone in West Virginia abuse and neglect jurisprudence: acknowledgment is the threshold to meaningful treatment. Without it, courts view improvement periods—especially in sexual abuse cases—as essentially futile.

3.4.3 Application to the Mother’s Conduct

At the dispositional hearing, the mother:

Expressly denied sexually abusing W.W. or forcing him to abuse L.W.
Asserted that she did not need services to address sexual abuse.
Admitted she had “not taken any steps” to address abuse because she perpetually denied committing any.
Claimed she would do “whatever” was needed, but in substance only to pursue reunification, not to address sexual abuse.

The Supreme Court agreed with the circuit court that this posture failed the statutory burden:

Merely saying “I’ll do whatever” is insufficient if the parent simultaneously denies the core findings of abuse.
Without accepting that sexual abuse occurred, the mother could not meaningfully engage in sex offender treatment or related therapeutic services.
Thus, her own testimony demonstrated that she was not likely to fully participate in an improvement period that would realistically address the causes of abuse.

The Court concluded an improvement period would have been futile and that the circuit court did not abuse its discretion in denying it.

3.5 Termination of Parental Rights and Less Restrictive Alternatives

3.5.1 Statutory Dispositions: § 49‑4‑604(c)

The mother argued that termination was unnecessary and that the circuit court should have used a less restrictive alternative, namely disposition under West Virginia Code § 49‑4‑604(c)(5), which allows:

Temporary commitment of the child “to the care, custody, and control of the department, a licensed private child welfare agency, or a suitable person who may be appointed guardian by the court.”

However, § 49‑4‑604(c)(5) requires a finding that the abusing parent is “presently unwilling or unable to provide adequately for the child’s needs.” The Supreme Court contrasted this with § 49‑4‑604(c)(6), which authorizes termination of parental rights when:

There is no reasonable likelihood that the conditions of abuse or neglect can be substantially corrected in the near future; and
Termination is necessary for the child’s welfare.

The circuit court made both findings under subsection (c)(6), and the mother did not challenge those findings on appeal.

3.5.2 No Requirement to Use Less Restrictive Alternatives First

The Supreme Court relied on a well-established line of authority:

In re Kristen Y., 227 W. Va. 558, 712 S.E.2d 55 (2011) (Syllabus Point 5, in part):
“Termination of parental rights… may be employed without the use of intervening less restrictive alternatives when it is found that there is no reasonable likelihood under [West Virginia Code § 49‑4‑604(c)(6)] that conditions of neglect or abuse can be substantially corrected.”
(quoting Syllabus Point 2, In re R.J.M., 164 W. Va. 496, 266 S.E.2d 114 (1980))

The key message: once the statutory criteria of § 49‑4‑604(c)(6) are met, the circuit court is authorized—and often expected—to terminate; it is not required to step through every lesser dispositional option first if those options would not protect the child fully or would be inconsistent with the finding that there is no reasonable likelihood of correction.

Here:

The court concluded that the mother’s ongoing denial of sexual abuse made correction of the underlying conditions impossible in the near future.
Given the nature of the conduct (intrafamilial child sexual abuse) and the child’s firm desire not to see the mother, continued legal ties to the mother were incompatible with the children’s welfare.

3.5.3 Termination Where the Other Parent Has Custody

Finally, the Supreme Court addressed the mother’s argument that termination was unnecessary because the children had permanency with the father. Relying on:

In re Emily, 208 W. Va. 325, 540 S.E.2d 542 (2000):
The Court reiterated that § 49‑4‑604 “permits the termination of one parent’s parental rights while leaving the rights of the nonabusing parent completely intact, if the circumstances so warrant.”

Thus:

The mere fact that there is a fit, nonabusing parent (here, the father) who can provide permanency does not bar termination of the abusing parent’s rights.
Instead, the focus remains on whether the abusive parent’s relationship with the child can be safely preserved and whether continued legal ties are compatible with the child’s welfare.

The Supreme Court agreed that in this case, given the nature of the abuse and the mother’s steadfast denial, termination was appropriate notwithstanding the father’s intact custodial rights.

3.6 Precedents Cited and Their Influence

To synthesize, each cited case plays a distinct role in the opinion’s logic:

In re Cecil T., 228 W. Va. 89, 717 S.E.2d 873 (2011) – provided the standard of review (clear error for fact, de novo for law) guiding the Court’s assessment of the circuit court’s findings.
In re K.P., 235 W. Va. 221, 772 S.E.2d 914 (2015) – established that a child victim’s uncorroborated testimony can alone constitute clear and convincing evidence of sexual abuse, removing any legal foundation for the mother’s “uncorroborated” argument.
In re D.S., 251 W. Va. 466, 914 S.E.2d 701 (2025) and Michael D.C. v. Wanda L.C., 201 W. Va. 381, 497 S.E.2d 531 (1997) – underscored appellate deference to trial-level credibility determinations, precluding the Supreme Court from revisiting the circuit court’s decision to believe W.W. and disbelieve the mother.
In re Tonjia M., 212 W. Va. 443, 573 S.E.2d 354 (2002) – reaffirmed that improvement periods are discretionary and may be denied where no meaningful improvement is likely.
In re Timber M., 231 W. Va. 44, 743 S.E.2d 352 (2013) and In re Charity H., 215 W. Va. 208, 599 S.E.2d 631 (2004) – provided the foundational rule that a parent must acknowledge the basic truth of the abuse before the problem becomes amenable to treatment; otherwise, improvement periods become “futile.”
In re Kristen Y., 227 W. Va. 558, 712 S.E.2d 55 (2011) and In re R.J.M., 164 W. Va. 496, 266 S.E.2d 114 (1980) – clarified that once the § 49‑4‑604(c)(6) standard is met (no reasonable likelihood of correction and necessity for the child’s welfare), termination can be ordered without resorting to less restrictive dispositional alternatives.
In re Emily, 208 W. Va. 325, 540 S.E.2d 542 (2000) – confirmed that the statutory scheme allows termination of one parent’s rights while leaving the nonabusing parent’s rights intact, directly answering the mother’s argument that permanency with the father made termination unnecessary.

In combination, these precedents form a consistent doctrinal framework that the Supreme Court simply applied, rather than reshaped, in In re W.W. and L.W.

3.7 Legal Reasoning Synthesized

The Court’s reasoning can be summarized as a chain:

Evidence of Abuse: W.W.’s disclosures, supported by professional testimony and the circuit court’s credibility findings, met the clear and convincing standard under In re K.P..
Credibility and Appellate Review: The circuit court believed W.W. and disbelieved the mother; under D.S. and Michael D.C., the Supreme Court would not disturb those determinations.
Adjudication: Based on these findings, the mother was properly adjudicated an abusing parent; the children were properly adjudicated abused.
Improvement Period: The mother never acknowledged any abuse and saw no need for sexually oriented remedial services, making meaningful treatment impossible and any improvement period futile under Timber M./Charity H. and committed to the circuit court’s discretion under Tonjia M..
Termination: Her denial, coupled with the severe nature of sexual abuse, supported the unchallenged findings of no reasonable likelihood of correction and necessity for the children’s welfare under § 49‑4‑604(c)(6).
No Need for Less Restrictive Alternatives: In light of Kristen Y. and R.J.M., the circuit court was authorized to terminate without first imposing less restrictive dispositions.
One Parent Termination: Under Emily, the existence of a fit father with custody did not bar termination of the mother’s rights.

Thus, each assignment of error falls away when mapped onto the governing statutes and controlling caselaw.

3.8 Anticipated Impact and Practical Implications

While In re W.W. and L.W. is a memorandum decision largely applying established law, it consolidates several critical themes likely to influence practice in future cases:

Child Sexual Abuse Cases and Evidentiary Sufficiency.
The decision reinforces that:
- Consistent child disclosures, even without physical or independent corroboration, can be sufficient to support adjudication and termination.
- Practitioners should focus on the consistency and credibility of the child’s narrative across contexts (therapeutic, forensic, judicial) rather than fixating on corroborative evidence that often does not exist in sexual abuse cases.
Centrality of Parental Acknowledgment.
The ruling underscores an implicit “acknowledgment requirement” in seeking improvement periods:
- Parents who continue to deny adjudicated sexual abuse are unlikely to secure or benefit from improvement periods.
- Attorneys advising such parents must grapple with the reality that, in West Virginia law, accountability is effectively a precondition to reunification efforts, especially in sexual abuse contexts.
Termination Despite an Intact Nonabusing Parent.
Reaffirming Emily, the Court makes clear that:
- The presence of a fit custodial parent (here, the father) does not shield the abusing parent from termination.
- Termination may be appropriate to prevent future contact, avoid forced legal ties, and provide emotional safety and clarity for the child.
Strategic Use of Forensic and In Camera Interviews.
Although the transcript of the forensic interview did not appear in the appendix, the circuit court’s decision to take judicial notice and the Supreme Court’s deference highlight:
- The critical role of forensic interviewing and in camera testimony in building a record in child sexual abuse cases.
- The importance for counsel of ensuring these materials are properly before the circuit court and, ideally, preserved in the appellate record.
Separation from Criminal Proceedings.
The Court’s refusal to address the dismissed amended petition linked to the mother’s criminal charges underscores that:
- Abuse and neglect proceedings are civil and can proceed—and reach findings of sexual abuse—independently of the criminal process.
- The dismissal or resolution of related criminal charges does not control the outcome of the civil child-protection case.

4. Clarification of Key Legal Concepts

The opinion uses several legal terms of art that can be briefly clarified:

Abusing Parent: A parent who has committed abuse or neglect as defined by statute (here, sexual abuse and compelling one child to abuse another). Adjudication as an “abusing parent” is the formal legal finding at the adjudicatory stage.
Adjudication vs. Disposition:
- Adjudication: The stage where the court determines whether the child is abused or neglected and whether the parent is an abusing or neglecting parent, using the clear and convincing evidence standard.
- Disposition: The stage where the court decides what remedies or orders to enter—ranging from in‑home services to removal, improvement periods, or termination.
Clear and Convincing Evidence: A medium‑high standard of proof, requiring evidence that produces in the fact-finder a firm belief or conviction about the allegations’ truth. It is more demanding than “preponderance of the evidence” but less than “beyond a reasonable doubt.”
Improvement Period: A time-limited, court-supervised period during which a parent engages in services designed to correct conditions of abuse or neglect. It is not automatic; the parent must show by clear and convincing evidence that they are likely to fully participate.
Futility (in Improvement Periods): If a parent will not acknowledge core findings of abuse (particularly sexual abuse), then therapeutic and remedial services cannot meaningfully address the problem, making improvement “untreatable” and rendering the improvement period “an exercise in futility.” Courts will not order an improvement period at the child’s expense under such circumstances.
No Reasonable Likelihood of Correction: A statutory finding that the abusive conditions (e.g., sexual abuse, dangerous parenting behavior) are unlikely to be remedied in the near future. Persistent denial of abuse is a strong indicator of such unlikelihood.
Less Restrictive Alternatives: Dispositional options less severe than termination—such as temporary custody transfers, in‑home services, or legal guardianships. Under West Virginia law, once the § 49‑4‑604(c)(6) standard is met, courts are not obligated to use these lesser options before terminating.
Termination of Parental Rights: The most severe dispositional option, completely severing the legal parent–child relationship (custody, decision-making, inheritance, etc.). After termination, the parent no longer has statutory rights in relation to the child.

5. Conclusion

In re W.W. and L.W. does not announce new doctrine but powerfully reaffirms and concretizes existing West Virginia law in a particularly sensitive context—intricate, long‑term intrafamilial child sexual abuse. It illustrates how:

Credible, consistent child disclosures, even if uncorroborated, can sustain an adjudication of abuse and support termination of parental rights.
Parental refusal to acknowledge sexual abuse all but forecloses the possibility of a meaningful improvement period and leads inexorably toward a finding that conditions cannot be corrected.
Termination of the abusing parent’s rights is not rendered unnecessary or improper simply because the other parent is fit and the children have already achieved permanency with that parent.

Taken together, the decision sends a clear message: in West Virginia’s abuse and neglect system, the child’s safety and psychological well‑being are paramount. Where a child’s credible testimony reveals serious sexual abuse and the perpetrating parent refuses to accept responsibility, courts will not prolong proceedings through ineffective improvement periods or retain legal ties that put the child at risk. Even in memorandum form, In re W.W. and L.W. stands as a pointed illustration of how firmly those principles are now embedded in the state’s child-protection jurisprudence.