In re H.F.: Failure to Complete Inpatient Treatment and Provide Corroboration as Grounds for Termination of Parental Rights in West Virginia

In re H.F.: Failure to Complete Inpatient Treatment and Provide Corroboration as Grounds for Termination of Parental Rights in West Virginia

I. Introduction

The Supreme Court of Appeals of West Virginia’s memorandum decision in In re H.F., S.F., and L.F. (No. 24-577, Nov. 4, 2025) affirms the termination of a mother’s parental rights based on her persistent substance abuse, refusal to complete inpatient treatment, and lack of cooperation in providing treatment records. Although issued as a memorandum decision under Rule 21 of the West Virginia Rules of Appellate Procedure (and therefore without new syllabus points), the opinion meaningfully illustrates and reinforces several important principles in abuse and neglect law:

  • How a parent’s failure to complete inpatient drug treatment, when that treatment is a central component of the case plan, supports a finding that there is “no reasonable likelihood” of correcting conditions in the near future.
  • The role of uncorroborated, self-serving testimony about sobriety and treatment (e.g., Vivitrol use and negative drug screens), and why a circuit court is not obliged to accept it.
  • That considering a parent’s failure to produce corroborating records does not constitute impermissible burden shifting in abuse and neglect proceedings.
  • The broad discretion of circuit courts to deny continuances at disposition when a parent has had ample time to obtain records.
  • The continued centrality of the statutory standard under W. Va. Code § 49-4-604 and the doctrine that termination may occur without intervening less restrictive alternatives when correction is unlikely.

This commentary examines the factual background, the Court’s reasoning, the precedents cited, and the broader impact of the decision within West Virginia’s child welfare framework.

II. Summary of the Opinion

A. Background and Procedural History

In February 2024, the West Virginia Department of Human Services (“DHS”) filed an abuse and neglect petition against Petitioner Mother B.F. regarding several children, including H.F., S.F., and L.F. The petition alleged:

  • Physical and emotional abuse of the children;
  • Exposure of the children to domestic violence in the home; and
  • Other concerns relating to the children’s safety and wellbeing.

In March 2024, DHS amended its petition to add allegations of substance abuse after the mother tested positive for multiple drugs, including fentanyl and methamphetamine.

At the adjudicatory hearing in April 2024, the mother stipulated to key allegations, including:

  • That she exposed the children to domestic violence; and
  • That her substance abuse detrimentally affected the children.

Based on this stipulation, the circuit court adjudicated her as a neglectful parent. The mother moved for a post-adjudicatory improvement period; the court held that motion in abeyance pending approval of a case plan by the multidisciplinary team (“MDT”).

B. Case Plan and Inpatient Treatment Requirement

The MDT developed a case plan but insisted that the petitioner successfully complete inpatient drug rehabilitation before the case plan would be approved. At a May 2024 status hearing, the mother participated by telephone from an inpatient program at Harmony Ridge. DHS and the guardian ad litem (“GAL”) indicated they would not object to moving forward with her case plan if she completed that program.

However, at a June 2024 hearing to approve the case plan, evidence showed that the mother had left Harmony Ridge against medical advice (“AMA”) without completing the program. The circuit court stressed that successful completion of inpatient treatment was a condition of the case plan.

The mother, through counsel, represented that:

  • She was receiving a Vivitrol injection to treat her substance abuse; and
  • She would pass a drug screen.

The court directed her to sign a release authorizing DHS to obtain her treatment records. She refused, stating that DHS did not need her rehab information and that some of it was “not anybody’s business.” Her behavior became “flippant, arrogant, and extremely disruptive,” to the point that the court had to remove her from the courtroom.

Following this hearing:

  • The mother moved for a post-dispositional improvement period (i.e., an additional opportunity to correct issues after adjudication and during/after disposition);
  • DHS and the GAL, by contrast, recommended termination of parental rights.

C. Dispositional Hearing and Termination

At the August 2024 dispositional hearing, DHS presented the following key evidence:

  • The MDT had clearly informed the mother that completing inpatient substance abuse treatment was the most important step in addressing her neglect.
  • A bed had been made available for her at a second inpatient facility in May 2024, but she failed to attend.
  • She had left Harmony Ridge without completing the program.
  • This was the third abuse and neglect case involving the mother as a respondent.
  • DHS had already exhausted its rehabilitative resources with her in prior proceedings, including:
    • Parenting and adult life skills classes;
    • Individual counseling focused on domestic violence;
    • Drug counseling.
    Inpatient drug treatment was the only service not previously tried, hence its centrality in this case.
  • The mother continued to have positive drug screens during the case.

At the close of DHS’s case:

  • The mother moved to continue the dispositional hearing so she could obtain:
    • Documentation of her alleged Vivitrol treatment; and
    • Drug screen results purportedly showing she was drug-free.
  • DHS and the GAL objected.
  • The circuit court denied the continuance, noting that the hearing had been on the calendar for about two months and that she had not used that time to gather the evidence.

The mother testified that:

  • She was currently receiving Vivitrol; and
  • She was no longer using drugs.

She also blamed her drug use on the removal of the children, claiming she “wouldn’t be on drugs if you wouldn’t take my kids for nothing.” She confirmed that she did not complete inpatient treatment.

The circuit court found:

  • The mother had a “pervasive drug addiction.”
  • She refused to complete inpatient treatment, despite the MDT’s and court’s clear instructions.
  • Her testimony showed a lack of insight into her addiction and “negated her own stipulations” made earlier in the case.
  • Her claims about Vivitrol and sobriety were not supported by any corroborating documentation.
  • She was uncooperative throughout the case and failed to maintain contact with DHS.

The court:

  • Denied her motion for a post-dispositional improvement period;
  • Found no reasonable likelihood that she could substantially correct the conditions of neglect in the near future; and
  • Found termination to be in the children’s best interests.

Accordingly, it terminated her parental rights to the three children. The father of the children successfully completed his improvement period, and the permanency plan is for the children to remain in his custody.

D. Appeal and Holding

On appeal, the mother raised a single assignment of error: that the evidence was insufficient to support termination of her parental rights.

She argued in particular that:

  • The “uncontroverted” evidence showed she was in treatment and not using drugs;
  • The court improperly discounted her testimony about Vivitrol and sobriety; and
  • The court effectively shifted the burden of proof to her by faulting her for not producing corroborating records.

The Supreme Court of Appeals:

  • Applied the standard of review from In re Cecil T.: clear error for facts, de novo for law.
  • Rejected the mother’s sufficiency argument, emphasizing that:
    • There was abundant evidence of her non-compliance with inpatient treatment requirements;
    • The MDT had deemed inpatient treatment critical; and
    • DHS had previously exhausted other forms of services with her.
  • Held that credibility determinations and the weight assigned to uncorroborated testimony are for the circuit court, citing Michael D.C. v. Wanda L.C.
  • Found no abuse of discretion in the denial of the continuance, citing In re Mark M. and State v. Bush.
  • Found no merit in the burden-shifting argument, explaining (relying on In re K.V. and In re S.C.) that the burden of proof never shifted from DHS; the court simply noted the absence of corroboration for her claims.
  • Affirmed the circuit court’s finding under W. Va. Code § 49-4-604(d)(3) that there was no reasonable likelihood of correction because she failed to follow through with a reasonable case plan.
  • Held that termination under § 49-4-604(c)(6) was proper and that no less restrictive alternative was required, reaffirming In re Kristin Y. and In re R.J.M..

The Court therefore affirmed the termination of the mother’s parental rights.

III. Detailed Legal Analysis

A. Statutory and Procedural Framework

1. Abuse and Neglect Proceedings

West Virginia abuse and neglect proceedings follow a structured process:

  1. Petition and Adjudication – DHS files a petition alleging abuse and/or neglect. At the adjudicatory hearing, the court determines whether the allegations are proven (often by evidence or stipulation). Here, the mother stipulated to domestic violence exposure and substance-abuse-related neglect.
  2. Case Planning and Improvement Periods – If adjudicated, the court may grant an improvement period (post-adjudicatory or post-dispositional), giving the parent an opportunity, under a case plan, to correct conditions.
  3. Disposition – At disposition, the court decides the final remedy (return to parent, guardianship, termination, etc.), guided by W. Va. Code § 49-4-604.

2. “No Reasonable Likelihood of Correction” – § 49-4-604(d)(3)

Under W. Va. Code § 49-4-604(d)(3), a circuit court may find there is “no reasonable likelihood that conditions of neglect or abuse can be substantially corrected in the near future” when:

“[t]he abusing parent … [has] not responded to or followed through with a reasonable family case plan or other rehabilitative efforts.”

This provision is central in this case. The mother repeatedly:

  • Failed to complete inpatient treatment (even after checking in);
  • Declined to attend a second available program; and
  • Had a long history of previous services that did not resolve her issues.

Given these facts, the Supreme Court agreed that the circuit court properly applied § 49-4-604(d)(3).

3. Termination of Parental Rights – § 49-4-604(c)(6)

Under W. Va. Code § 49-4-604(c)(6), the court may terminate parental rights:

“[u]pon a finding that there is no reasonable likelihood that the conditions of neglect or abuse can be substantially corrected in the near future and, when necessary for the welfare of the child.”

Thus, to terminate, the court must find:

  1. No reasonable likelihood of substantial correction in the near future; and
  2. That termination is necessary for the child’s welfare (best interests).

Here, those findings rested on:

  • The mother’s persistent, untreated substance abuse;
  • Her refusal to complete the core rehabilitative component (inpatient treatment);
  • Her lack of insight and refusal to accept responsibility; and
  • The need for permanency and stability for the children, who had a father ready and able to provide care.

4. Less Restrictive Alternatives vs. Immediate Termination

The mother argued implicitly that the court should have chosen a less restrictive disposition, such as:

  • Another improvement period; or
  • A less drastic custodial arrangement under § 49-4-604(c)(5).

The Supreme Court relied on In re Kristin Y. (quoting In re R.J.M.) to reaffirm that:

“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 that conditions of neglect or abuse can be substantially corrected.” (emphasis added)

Because the trial court properly found no reasonable likelihood of correction, it was not required to first attempt less restrictive options.

B. Precedents Cited and Their Influence

1. In re Cecil T., 228 W. Va. 89, 717 S.E.2d 873 (2011)

The Court cites Syllabus Point 1 of In re Cecil T. for the standard of review:

  • Findings of fact are reviewed for clear error – the appellate court will not disturb them unless left with a firm and definite conviction that a mistake has been made.
  • Conclusions of law are reviewed de novo – the Court gives no deference to the lower court’s legal conclusions.

This sets the framework for affirming the circuit court’s factual findings about:

  • The mother’s non-compliance;
  • Her behavior and credibility; and
  • The adequacy of DHS’s efforts.

2. Michael D.C. v. Wanda L.C., 201 W. Va. 381, 497 S.E.2d 531 (1997)

The Court quotes Michael D.C. to emphasize that:

“A reviewing court cannot assess witness credibility through a record. The trier of fact is uniquely situated to make such determinations and this Court is not in a position to, and will not, second guess such determinations.”

This directly addresses the mother’s argument that her testimony about receiving Vivitrol injections and passing drug screens was “uncontroverted.” Even if no direct contrary evidence was presented on those specific claims, the circuit court was:

  • Free to disbelieve her; and
  • Free to assign her testimony little weight, especially given:
    • Her prior conduct;
    • Her refusal to sign releases; and
    • Her disruptive behavior in court.

Thus, the case reinforces that uncorroborated, self-serving assertions of rehabilitation do not compel a finding that conditions have been remedied.

3. In re Mark M., 201 W. Va. 265, 496 S.E.2d 215 (1997) and State v. Bush, 163 W. Va. 168, 255 S.E.2d 539 (1979)

The mother asked for a continuance at the end of DHS’s case at disposition. The Court cites:

  • Syllabus Point 3, In re Mark M., which in turn quotes:
    • Syllabus Point 2 of State v. Bush: “A motion for continuance is addressed to the sound discretion of the trial court, and its ruling will not be disturbed on appeal unless there is a showing that there has been an abuse of discretion.”

The Supreme Court upheld the denial of a continuance because:

  • The dispositional hearing was scheduled well in advance (about two months);
  • The mother knew of the importance of treatment documentation; and
  • She failed to pursue those records in a timely manner.

The decision underscores that late, strategic requests for continuances to obtain evidence that could have been gathered earlier will generally be disfavored, especially where children’s permanency is at stake.

4. In re K.V., 251 W. Va. 418, 914 S.E.2d 517 (2025) and In re S.C., 168 W. Va. 366, 284 S.E.2d 867 (1981)

The mother argued that the circuit court improperly shifted the burden of proof to her by criticizing her failure to produce evidence of Vivitrol treatment and clean drug screens. The Supreme Court quoted from:

  • In re K.V., Syllabus Point 3 (in part), which reiterates the long-standing rule from
  • In re S.C., Syllabus Point 2, that:
    “the burden of proof in a child neglect or abuse case does not shift from the [DHS] to the parent, guardian or custodian of the child.”

However, the Court explained that the circuit court did not in fact shift the burden. Rather, it:

  • Recognized that DHS had met its burden through substantial evidence of neglect and non-compliance; and
  • Merely noted that the mother’s own assertions about treatment and sobriety were unsupported by objective evidence, and could therefore be discounted.

This is a subtle but important clarification:

  • DHS always must prove abuse/neglect and the statutory grounds for disposition (including termination);
  • Yet, a parent’s failure to produce documentation supporting their claimed rehabilitation can legitimately affect the weight afforded to their testimony, without shifting the legal burden.

5. 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)

To address the mother’s lack of insight and denial of responsibility, the Court cited In re Timber M., which in turn quotes In re Charity H.:

“Failure to acknowledge the existence of the problem … results in making the problem untreatable….”

This principle is crucial in substance abuse and domestic violence cases:

  • Courts and treatment providers cannot meaningfully treat a problem that the parent denies or minimizes.
  • Here, the mother:
    • Blamed DHS for her drug use (“wouldn’t be on drugs if you wouldn’t take my kids for nothing”); and
    • Engaged in disruptive conduct and refused information-sharing that would have supported her claimed recovery.

The Court concluded that her failure to acknowledge her role in the conditions of neglect made meaningful treatment unlikely and supported termination.

6. In re Kristin 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)

The Court relies on In re Kristin Y., particularly Syllabus Point 5 (in part, quoting In re R.J.M.), to reaffirm:

“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 that conditions of neglect or abuse can be substantially corrected.”

This allows trial courts to:

  • Terminate parental rights directly, without another improvement period or a less drastic custodial arrangement, when:
  • The statutory “no reasonable likelihood” standard is satisfied; and
  • Termination is necessary for the child’s welfare.

In In re H.F., this precedent confirms that the circuit court’s direct move to termination was appropriate in light of the mother’s history and ongoing non-compliance.

C. The Court’s Legal Reasoning in Depth

1. Evidentiary Sufficiency and “Uncontroverted” Claims

The mother framed the evidence in her favor as “uncontroverted,” emphasizing:

  • Her testimony that she was on Vivitrol; and
  • Her assertion that she was no longer using drugs.

The Supreme Court rejected this characterization for two reasons:

  1. Credibility and Weight of Evidence – Under Michael D.C., the circuit court, as factfinder, has the authority to:
    • Assess demeanor and credibility;
    • Weigh conflicting narratives; and
    • Assign minimal weight to testimony that appears self-serving or inconsistent with other facts.
    The fact that DHS did not produce contrary medical evidence regarding Vivitrol did not require the court to accept her claims.
  2. Lack of Corroboration – The trial court had already tried to obtain objective data (treatment records). The mother:
    • Refused to sign releases;
    • Then sought a last-minute continuance to gather evidence she had months to obtain; and
    • Provided no documents to substantiate her alleged compliance.
    The Supreme Court endorsed the trial court’s decision to treat her unsupported assertions as insufficient to counter the extensive evidence of ongoing addiction and non-compliance.

2. Non-Compliance with Inpatient Treatment as Central to “No Reasonable Likelihood”

The MDT and the circuit court consistently identified inpatient substance abuse treatment as the “most critical step” in remedying neglect. DHS had already provided extensive services in prior proceedings (parenting education, counseling, etc.), none of which resolved the underlying issues.

The Court’s reasoning implies a logical structure:

  1. Reasonable Case Plan – Requiring inpatient treatment was reasonable, particularly given:
    • The severity of the mother’s addiction (including fentanyl and methamphetamine);
    • The failure of lesser interventions; and
    • The need for a structured, intensive environment to achieve sustained sobriety.
  2. Non-Compliance – The mother did not:
    • Complete Harmony Ridge (left AMA); or
    • Avail herself of a second inpatient placement arranged by DHS.
  3. Statutory Consequence – Under § 49-4-604(d)(3), her failure to follow through with the reasonable family case plan supports a finding that she cannot substantially correct the conditions of neglect in the near future.

This analysis shows how specific, treatment-focused non-compliance can independently justify the “no reasonable likelihood” finding.

3. Burden of Proof vs. Evidentiary Persuasion

The mother’s burden-shifting argument conflated two separate ideas:

  • Legal burden of proof – Always remains on DHS to prove abuse/neglect and the statutory grounds for disposition.
  • Evidentiary weight – How much persuasive value the factfinder assigns to each piece of evidence, including a parent’s testimony about rehabilitation.

By emphasizing the absence of corroborating records, the circuit court was:

  • Explaining why it did not find her testimony persuasive; not
  • Requiring her to disprove DHS’s case as a matter of legal burden.

The Supreme Court’s discussion, grounded in In re K.V. and In re S.C., clarifies that:

  • Courts may legitimately observe that objective proof is missing where it would normally exist (e.g., medical records, lab results);
  • Such observation is not the same as demanding that the parent carry the burden of persuasion.

4. Denial of Continuance at Disposition

The timing of the mother’s motion for continuance was critical. The Court pointed out that:

  • The dispositional hearing was scheduled for approximately two months;
  • The importance of treatment records had been made clear earlier in the case;
  • She had not pursued those records or signed releases when requested; and
  • Children’s cases require timely permanency—continued delay undermines their best interests.

Under Mark M. and Bush, the abuse-of-discretion standard gives trial courts broad leeway to deny continuances where:

  • The requesting party has not acted diligently; and
  • The delay would harm the interests of the children in achieving stability.

In re H.F. illustrates that appellate courts are unlikely to reverse such denials when the parent had ample opportunity to prepare.

5. Best Interests and the Role of the Non-Abusing Parent

The Court affirmed that termination was in the children’s best interests, noting that:

  • The father successfully completed his improvement period; and
  • The permanency plan is for the children to remain with him.

West Virginia law allows termination of one parent’s rights while preserving the rights of a non-abusing or rehabilitated parent. This arrangement:

  • Promotes stability and permanency for the children; and
  • Is consistent with the statutory focus on the child’s welfare rather than the adult’s interests alone.

D. Impact and Future Significance

1. Treatment Records and Cooperation: Practical Lessons

The decision underscores a practical message to parents in abuse and neglect cases:

  • Objective documentation (rehab records, drug test results, treatment compliance reports) carries significant weight.
  • Refusing to sign releases or to share treatment information with DHS or the court:
    • Undermines credibility;
    • May cause the court to discount claims of sobriety or treatment; and
    • Can be factored into “no reasonable likelihood” analysis.

While patients retain rights to medical privacy, when child safety is at stake, courts are entitled to view non-cooperation as inconsistent with genuine rehabilitation.

2. Medication-Assisted Treatment (MAT) and Uncorroborated Sobriety Claims

Though the opinion does not elaborate on Vivitrol as a form of medication-assisted treatment (MAT), the case implicitly addresses a broader point:

  • Participation in MAT, by itself and without corroboration, does not automatically prove parental fitness or rehabilitation.
  • Courts will look to:
    • Completion of recommended programs;
    • Objective drug testing;
    • Consistent engagement with services; and
    • Behavioral changes and insight into addiction.

In cases where a parent relies on MAT, In re H.F. signals that they must be prepared to document compliance and sobriety with medical and laboratory records, not merely testimony.

3. Repeated System Involvement and Service Exhaustion

The Court gave weight to the fact that this was the mother’s third abuse and neglect case, and that DHS had already expended substantial resources providing services. This reinforces:

  • The principle that the child welfare system need not indefinitely repeat services that have repeatedly failed.
  • Courts may appropriately consider:
    • Past non-compliance;
    • Chronic patterns of behavior; and
    • Service “exhaustion”
    when evaluating whether further improvement periods would be productive.

4. Judicial Response to Disruptive Courtroom Conduct

The trial court described the mother’s conduct as “flippant, arrogant, and extremely disruptive,” and ultimately removed her from the courtroom. While the Supreme Court did not dwell on this fact procedurally, it clearly supported:

  • The trial court’s assessment of her lack of insight and accountability;
  • The inference that she was not yet ready to engage constructively in treatment and services; and
  • The conclusion that additional improvement periods were unlikely to succeed.

For practitioners, this underlines how demeanor and attitude in the courtroom can meaningfully affect judicial assessments in abuse and neglect cases.

IV. Key Legal Concepts Simplified

1. Abuse and Neglect Case

An abuse and neglect case is a civil proceeding where the State (via DHS) alleges that a child is abused or neglected—meaning the child’s safety, health, or welfare is harmed or threatened by a parent or guardian’s conduct or omissions.

2. Adjudication vs. Disposition

  • Adjudication – The stage where the court decides whether the parent has abused or neglected the child. In this case, the mother stipulated to neglect (domestic violence exposure and substance-abuse-related harm), so adjudication was straightforward.
  • Disposition – The stage where the court decides what to do about an adjudicated case (e.g., return the child, grant an improvement period, place the child out of the home, or terminate parental rights).

3. Improvement Period

An improvement period is a court-ordered time frame during which an abusing or neglectful parent is given an opportunity to correct the problems identified by DHS, under a structured case plan.

  • Post-adjudicatory improvement period – Occurs after the court has adjudicated neglect/abuse but before final disposition.
  • Post-dispositional improvement period – May be granted after an initial disposition in some circumstances.

Improvement periods are discretionary, not automatic. Courts can deny or revoke them if:

  • The parent fails to comply with the plan; or
  • The evidence shows that correction is unlikely in the near future.

4. Multidisciplinary Team (MDT)

An MDT in child welfare cases is a group of professionals—often including DHS workers, therapists, attorneys, guardians ad litem, and sometimes service providers—who collaboratively:

  • Evaluate the family’s situation;
  • Design a case plan; and
  • Make recommendations to the court about services and permanency.

Here, the MDT concluded that inpatient drug rehabilitation was the key service needed for this mother to safely parent her children.

5. “No Reasonable Likelihood of Correction”

This phrase, used in § 49-4-604(d), essentially asks:

Is it realistically likely that the parent will correct the problems (abuse/neglect) within a timeframe that makes sense for the child?

When the answer is “no,” based on evidence such as:

  • Repeated non-compliance with treatment;
  • Failure to use offered services; or
  • Denial of the underlying problem;

the court is authorized to terminate parental rights if that is necessary for the child’s welfare.

6. Memorandum Decision Under Rule 21

A memorandum decision under Rule 21 is a shorter appellate disposition used when:

  • The legal issues are controlled by existing precedent or statute; and
  • Oral argument is deemed unnecessary.

Such decisions typically do not create new syllabus points, but they can still provide valuable guidance on how existing law is applied to particular factual scenarios, as in In re H.F.

V. Conclusion

In re H.F., S.F., and L.F. reinforces several core principles in West Virginia abuse and neglect law:

  • When an MDT and the court reasonably identify inpatient treatment as the central requirement for rehabilitation, a parent’s failure to complete such treatment strongly supports a finding of “no reasonable likelihood” of correcting conditions under § 49-4-604(d)(3).
  • Uncorroborated, self-serving testimony about sobriety and treatment—including assertions about medications like Vivitrol and negative drug screens—need not be accepted by the court, especially when the parent:
    • Refuses to release treatment records;
    • Fails to obtain documentation despite ample time; and
    • Displays a lack of insight into the underlying problems.
  • Noting a parent’s failure to provide corroborating evidence does not amount to impermissible burden shifting; DHS retains the burden of proof, but credibility and evidentiary weight remain for the trial court to assess.
  • Denial of a continuance at disposition will generally be upheld when the parent had a reasonable opportunity to gather evidence earlier and children’s permanency interests weigh against delay.
  • Termination of parental rights may proceed without intermediate, less restrictive dispositions when the statutory criteria are met and termination is necessary for the children’s welfare, consistent with In re Kristin Y. and In re R.J.M..

As a practical matter, this decision sends a clear message: in abuse and neglect proceedings, parents who wish to avoid termination must not only engage in services but must meaningfully complete the most critical components of their case plans and be prepared to document their progress. For circuit courts, In re H.F. provides a robust, precedent-based roadmap for evaluating non-compliance, weighing uncorroborated claims of rehabilitation, and ensuring that the child’s right to a safe and permanent home remains paramount.

Case Details

Year: 2025
Court: Supreme Court of West Virginia

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