In re M.V.: ADA Accommodations, Parental Rights, and the Requirement to Acknowledge Child Sexual Abuse

I. Introduction

The Supreme Court of Appeals of West Virginia’s memorandum decision in In re M.V., No. 24-683 (Nov. 25, 2025), affirms the termination of a mother’s parental rights in a sexual abuse and neglect case, despite her claim that the Department of Human Services (“DHS”) failed to provide reasonable accommodations under the Americans with Disabilities Act of 1990 (“ADA”) during her court-ordered improvement period.

While issued as a memorandum decision under Rule 21 of the West Virginia Rules of Appellate Procedure, the opinion provides an important clarification at the intersection of child welfare law and disability law:

• ADA-based claims in abuse and neglect proceedings require a demonstrated denial of “meaningful access” to services and a nexus between the disability and the parent’s failure to remedy the conditions of abuse or neglect.
• Where the ground for termination is a parent’s knowing and willful refusal to acknowledge a child’s sexual abuse, and the evidence shows the parent is capable of understanding the abuse, the ADA does not bar termination, even if the parent has intellectual limitations.

The Court reaffirms the long-standing West Virginia principle that abuse and neglect problems are “untreatable” if the parent refuses to acknowledge them, and holds that this refusal—not any alleged failure of accommodation—made reunification with M.V. impossible in this case.

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II. Background and Procedural History

A. Parties and Allegations

• Child: M.V., approximately fourteen years old at disposition.
• Petitioner: R.P., the mother (“petitioner mother”).
• Respondent agency: West Virginia Department of Human Services (DHS).
• Guardian ad litem: Appointed for M.V., represented by counsel.

DHS filed an abuse and neglect petition in January 2024 alleging:

• Excessive corporal punishment by the mother; and
• Failure to protect M.V. from the mother’s boyfriend, whom the child reported as engaging in “physical touching of a sexual nature,” including:
  • Touching M.V.’s legs; and
  • Putting his hand down the back of her pants.

After M.V. disclosed the boyfriend’s conduct to Child Protective Services (“CPS”), she reported that when she tried to tell her mother about the inappropriate touching, the mother:

• Made her stand in the corner; and
• “Banged [the child’s] head against the wall” instead of protecting or reassuring the child.

B. Preliminary Hearing (February 2024)

At the contested preliminary hearing:

• The mother admitted she “smack[ed] [the child] in the mouth for running her mouth” and made the child stand in the corner for about thirty minutes.
• She denied that M.V. had reported inappropriate touching by the boyfriend and stated that she did not believe the child’s disclosures to CPS.
• She insisted the boyfriend “did nothing wrong” and acknowledged that she still allowed him in the home.

The circuit court recessed to allow the mother to view videos recorded by M.V. depicting the boyfriend’s inappropriate touching. After the videos were reviewed, the court found that imminent danger existed at the time of removal.

C. Adjudicatory Hearings (February–March 2024)

At adjudication, the circuit court heard:

• Testimony from a CPS worker about the allegations;
• Testimony from the boyfriend, who admitted that he was the person depicted touching the child’s leg and lower back in the videos; and
• In camera testimony from the child.

The hearing continued into March 2024. The mother testified that:

• She believed the child had fabricated the allegations;
• She saw “nothing sexual” in the videos;
• Although she and the boyfriend were no longer in a relationship, “if [the boyfriend] wanted to be around, he could be.”

Based on this record, the circuit court adjudicated the mother as a neglecting parent for:

• Her failure to protect M.V. from sexual abuse; and
• Her failure to separate her own needs from the child’s, as shown by her blaming the child and minimizing or denying the abuse.

Despite these concerns, the court granted the mother a post-adjudicatory improvement period.

D. Terms and Progress in the Improvement Period

At an April 2024 hearing, the mother acknowledged that she had reviewed and understood the terms of her improvement period and signed them. The terms required her to:

• Maintain regular communication with DHS;
• Complete a psychological evaluation;
• Attend parenting classes; and
• Participate in individual counseling.

Progress was mixed:

• She was assigned a parent coach in April 2024.
• By May 2024, her counsel reported that she had:
  • Met with her parent coach;
  • Started parenting classes; and
  • Completed the psychological evaluation.
• However, by June 2024, DHS moved to revoke the improvement period on the grounds that:
  • She had not begun individual counseling; and
  • She continued to deny the child’s allegations of sexual abuse.

E. Emergence of ADA Issues

In July 2024, the mother opposed DHS’s motion to revoke and raised, for the first time, an explicit reliance on the ADA. She stated that:

• Her psychological evaluation indicated that she “qualifie[d] for protection under the [ADA]” because of an “intellectual disability.”
• She “require[d] adaptive or modified services to achieve reunification.”

Crucially:

• She did not specify any particular accommodation or modification she needed; and
• She did not claim that she misunderstood the terms of the improvement period.

By September 2024, the court determined that the mother still had not begun individual counseling and set the case for a dispositional hearing.

F. Dispositional Hearing (October 2024)

At disposition, the circuit court considered:

1. DHS testimony

• The mother had not communicated regularly with DHS.
• She had not requested contact or visitation with the child during the proceedings.
• She did not begin individual counseling until October 2024, just before disposition.
• DHS recommended termination of her parental rights, which was also the expressed wish of M.V.
• On cross-examination, the worker admitted DHS did not formally modify the written terms of the improvement period after learning of the mother’s intellectual limitations.

2. Psychological evaluation

The court admitted the written psychological evaluation. The evaluating psychologist found:

• The mother’s general cognitive ability fell within the borderline to low average range.
• She could have difficulty keeping up with peers in situations requiring more advanced thinking and reasoning.
• The report, however, did not recommend any specific additional or modified services.
• Her prognosis was “guarded,” largely because she insisted that the child was lying about the abuse.

3. Treating psychologist’s testimony

The mother’s treating psychologist (who did not conduct a separate evaluation, but relied on the report) testified that:

• The mother had impairments in working memory and processing speed, affecting her capacity to process verbally given information and to problem-solve.
• Accordingly, information needed to be given in a “very concrete and simple manner.”
• She and her colleagues had been providing services in that concrete, simplified way through:
  • Recently initiated individual counseling; and
  • “Therapeutic mentoring” parenting services, begun in July 2024.
• She testified there was “nothing wrong with how the [improvement period’s] terms . . . were written,” and that the mother’s intellectual limitations did not prevent her from understanding that the child had been sexually abused.
• The mother still had not acknowledged the sexual abuse, and the psychologist explained that without such acknowledgment, family therapy with the child could not ethically proceed.

4. Mother’s testimony

The mother testified that:

• She participated in services and requested supervised visitation.
• She experienced no difficulty with everyday life, was employed, and owned a home and vehicle—facts that cut against a claim of very significant functional impairment.
• She characterized the case as arising from “[s]exual abuse that never happened.”
• She acknowledged that her psychologist could not promote family therapy toward reunification if the mother insisted no abuse had occurred, but maintained: “It’s not my belief. It’s the truth.”
• She admitted posting on social media in September 2024 that the child was lying and that she would not apologize for her relationship with the boyfriend, whom she loved and “would have married,” knowing the child could view this post.

5. Circuit court’s findings at disposition

Based on this evidence, the circuit court found that:

• The mother could not accept “the child’s truth that [she] was a victim of [the boyfriend’s] sexual abuse,” which “totally destroyed [the mother’s] ability to reunify” with M.V.
• She remained emotionally entrenched at the beginning of the case, continuing to put her own needs—and the boyfriend—above the child’s safety.
• She made “extremely poor choices,” including the social media post accusing the child of lying.
• It was not substantially likely that the mother would change in the near future.
• Given her inability or unwillingness to protect the child, there was no less restrictive alternative than termination of parental rights.

The court terminated the mother’s parental rights (and also the father’s) and ordered that M.V.’s permanency plan would be adoption in the current placement.

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III. Summary of the Supreme Court’s Opinion

On appeal, the mother raised a single argument: that DHS violated the ADA and West Virginia Code § 49-4-604(a)(1) by failing to provide reasonable accommodations for her disability during the improvement period, and therefore the termination order was erroneous.

The Supreme Court of Appeals:

• Applied the usual standard of review for abuse and neglect cases:
  • Findings of fact: reviewed for clear error; and
  • Conclusions of law: reviewed de novo (citing Syl. Pt. 1, In re Cecil T., 228 W. Va. 89, 717 S.E.2d 873 (2011)).
• Rejected the ADA argument, concluding:
  • The record did not support a finding that DHS denied the mother reasonable accommodations necessary for “meaningful access to reunification and family preservation services.”
  • The mother never identified or requested any specific accommodation at any point in the proceedings.
  • The treating psychologist’s testimony established that services were in fact modified to account for the mother’s cognitive limitations (e.g., concrete and simplified explanations).
• Emphasized that the termination decision rested not on any consequence of the mother’s alleged disability, but on her resolute refusal to acknowledge the child’s sexual abuse by the boyfriend.
• Reaffirmed that abuse and neglect conditions are “untreatable” if the parent refuses to acknowledge the underlying problem, citing:
  • 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).
• Held that there was no reasonable likelihood that the conditions of neglect could be substantially corrected in the near future and that termination was necessary for the child’s welfare, satisfying W. Va. Code § 49-4-604(c)(6).

The Court therefore affirmed the October 25, 2024, order terminating the mother’s parental rights.

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IV. Precedents and Authorities Cited

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

In re Cecil T. provides the standard of appellate review in West Virginia abuse and neglect cases, quoted in syllabus point 1:

On appeal from a final order in an abuse and neglect proceeding, this Court reviews the circuit court's findings of fact for clear error and its conclusions of law de novo.

In In re M.V., this standard frames the Court’s limited role: it does not reweigh evidence but examines whether:

• There is record support for the circuit court’s factual findings (e.g., the mother’s refusal to acknowledge abuse); and
• The circuit court properly applied the law (the ADA and W. Va. Code § 49-4-604) to those facts.

B. In re Timber M., 231 W. Va. 44, 743 S.E.2d 352 (2013)

In Timber M., the Court articulated a key principle that is central to In re M.V.:

[I]n order to 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.

This doctrine is often invoked where a parent refuses to accept:

• That the child has been abused or neglected; or
• That a particular alleged perpetrator (e.g., a partner, relative, or the parent themselves) is responsible.

In In re M.V., the Supreme Court applies this rule almost verbatim: the mother’s unyielding position that the sexual abuse “never happened,” combined with her minimization and blaming of the child, renders the neglect condition “untreatable.” No amount of services—modified or not—can succeed if the parent denies the factual predicate of the case.

C. In re Charity H., 215 W. Va. 208, 599 S.E.2d 631 (2004)

Charity H. is the earlier source of the “acknowledgment” doctrine later quoted in Timber M.. There, the Court made explicit that parental denial of the abuse or neglect allegations undermines the efficacy of remedial services.

In In re M.V., the Court cites Charity H. (through Timber M.) to reinforce that acknowledgment is not a mere formality: it is a substantive precondition for treating and resolving the harmful home environment.

D. Statutory Authorities

1. W. Va. Code § 49-4-604(a)(1): ADA accommodations in family case plans

The mother relied on W. Va. Code § 49-4-604(a)(1), which provides that family case plans must include:

any reasonable accommodations in accordance with the [ADA] to parents with disabilities in order to allow them meaningful access to reunification and family preservation services.

This statute effectively incorporates ADA principles into West Virginia’s child welfare system, mandating that DHS:

• Identify parental disabilities; and
• Design case plans that reasonably accommodate those disabilities so that parents can meaningfully access reunification services.

The Supreme Court in In re M.V. acknowledges this statutory requirement but concludes that:

• The record does not show that the mother was denied any accommodations necessary for meaningful access; and
• Her failure to reunify stemmed from her refusal to accept that sexual abuse occurred, not from her cognitive limitations.

2. W. Va. Code § 49-4-604(c)(6): Termination standard

The Court recites the familiar termination standard contained in W. Va. Code § 49-4-604(c)(6), which authorizes termination where:

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

In applying this standard, the Court focuses on:

• The mother’s ongoing prioritization of her own relationship with the boyfriend over the child’s safety; and
• Her persistent public and private messaging that the child was lying, including the September 2024 social media post.

These facts support the conclusion that the neglectful condition (failure to protect from sexual abuse and emotional harm from blaming the victim) would not be corrected in the near future.

E. Federal Authority: ADA, 42 U.S.C. § 12132 (Title II)

The opinion quotes the core prohibition of Title II of the ADA:

[N]o qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subject to discrimination by any such entity.

DHS, as a state agency, is a public entity under Title II. The mother’s theory is essentially that DHS:

• Failed to modify services to account for her intellectual disability; and thus
• Denied her the benefit of reunification services “by reason of” that disability.

The Supreme Court rejects this theory on both factual and legal causation grounds:

• Factually, services were modified and delivered in simplified, concrete form by her providers.
• Legally, the basis for termination was her voluntary choice to deny the abuse, not a barrier imposed “by reason of” any disability.

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V. The Court’s Legal Reasoning

A. The ADA and “Meaningful Access” to Services

The Court frames the key ADA inquiry as whether the mother was denied “meaningful access to reunification and family preservation services.” This is consistent with general ADA jurisprudence, which focuses less on perfect outcomes and more on whether:

• The person with a disability can effectively access and participate in the program; and
• Reasonable modifications and aids have been provided where needed.

Several aspects of the record underpin the Court’s conclusion that meaningful access was not denied:

1. Functional assessment of the mother’s abilities.
   The psychological evaluation placed her cognitive functioning in the borderline to low-average range, but:
   • It did not characterize her as severely impaired in basic daily functioning; and
   • It did not recommend specific modified or specialized services beyond what DHS was already offering.
2. Actual modifications in service delivery.
   The treating psychologist credibly testified that:
   • She and her colleagues adjusted their approach by presenting information “in a very concrete and simple manner” and providing “therapeutic mentoring” parenting services.
   • These modifications were tailored to the mother’s deficits in working memory and processing speed.
   Thus, even though the written terms of the improvement period were not formally rewritten, the practice of DHS providers reflected individualized accommodations.
3. No identified unmet accommodation request.
   The mother asserted she “qualifie[d] for protection under the [ADA]” and required adaptive services, but she:
   • Never specified what accommodations she needed; and
   • Never claimed that a particular service was incomprehensible or inaccessible because of her disability.
   The Court gives weight to this absence of a concrete accommodation request.
4. The mother’s own testimony about daily functioning.
   She testified that she:
   • Held employment;
   • Owned a home and vehicle; and
   • Handled day-to-day life without difficulty.
   These statements—while not dispositive—undermine the notion that her cognitive limitations created an insurmountable barrier to understanding and following through with standard (or modestly modified) services.

From these points, the Court concludes that the mother had meaningful access to services and that any deficits in performance were not attributable to a failure to accommodate.

B. The Nexus Requirement: Disability vs. Willful Denial

An implicit but crucial element of the Court’s reasoning is a nexus requirement: for an ADA-based challenge to succeed in the child welfare context, the parent must demonstrate some causal connection between:

• A disability; and
• The inability to remedy the conditions of abuse or neglect.

In In re M.V., the Court emphasizes that:

• The circuit court’s dispositional decision did not turn on any matter “affected in any way” by the reported disability, “should it exist.”
• Instead, the critical factor was the mother’s resolute refusal to accept that the child had been sexually abused, despite:
  • Seeing the videos;
  • Hearing testimony; and
  • Receiving counseling and other services presented in simplified, concrete terms.

The treating psychologist’s testimony was pivotal. She indicated that:

• The mother’s intellectual limitations did not prevent her from understanding that the child had been molested; and
• The barrier was the mother’s unwillingness—not her cognitive incapacity—to accept the reality of the abuse.

In other words, even granting that the mother is a “qualified individual with a disability,” the Court sees the termination decision as based on her voluntary choices, not discrimination “by reason of” her disability.

C. Application of the Acknowledgment Doctrine

Drawing on Timber M. and Charity H., the Court reiterates that:

• To remedy abuse and neglect, the parent must acknowledge:
  • The reality of the abusive or neglectful behavior; and
  • The identity of the perpetrator.
• Refusal to acknowledge renders the situation “untreatable.”

The facts in In re M.V. present a textbook application of this principle:

• The mother:
  • Denied the sexual abuse throughout the case;
  • Publicly accused the child of lying; and
  • Continued to emotionally align herself with the boyfriend.
• The guardian ad litem reported that the child wanted termination and adoption in the current placement.
• The treating psychologist testified that without the mother’s acknowledgment, family therapy could not even begin.

Given this, the Court affirms the circuit court’s conclusion that:

• There was no reasonable likelihood the mother would change her stance or correct the neglect condition in the near future; and
• Termination was necessary for M.V.’s welfare under W. Va. Code § 49-4-604(c)(6).

D. No Less Restrictive Alternative to Termination

In West Virginia, even when the statutory grounds for termination exist, the court must still consider whether a “less restrictive alternative” to full termination (e.g., continued improvement period, guardianship, or custodial arrangements) would adequately protect the child.

The circuit court, and the Supreme Court by affirmance, concluded that no such lesser option was viable because:

• The mother continued to minimize and deny the abuse, thus posing an ongoing risk that she would expose M.V. to the boyfriend or to similar perpetrators;
• The mother’s social media conduct showed a lack of insight into the emotional harm inflicted by accusing the child of lying in a public forum;
• The child’s stated preference for adoption in the current placement indicated that further delay or partial measures would be harmful to her sense of stability and safety.

These circumstances justified termination as the only measure that could reliably secure M.V.’s safety and emotional well-being.

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VI. Complex Concepts Simplified

The opinion uses or presupposes several specialized legal concepts. The following explanations may assist non-lawyers.

A. “Improvement Period”

An improvement period in West Virginia abuse and neglect cases is a court-supervised period during which a parent is given services and an opportunity to correct the conditions that led to the child’s removal. Typical components include:

• Parenting classes;
• Substance abuse treatment (if applicable);
• Counseling;
• Visitation; and
• Compliance with case plan terms (housing, employment, etc.).

If the parent makes sufficient progress, the court may reunify the family or extend the improvement period. If progress is insufficient or the parent is noncompliant, the court may move to terminate parental rights.

B. “Disposition” in Abuse and Neglect

The dispositional hearing is the final stage of an abuse and neglect case, where the court decides the permanent arrangement for the child. Options include:

• Returning the child home (with or without supervision);
• Placing the child with relatives or in foster care;
• Creating legal guardianship; or
• Terminating parental rights, typically to free the child for adoption.

C. “No Reasonable Likelihood the Conditions Can Be Substantially Corrected”

This statutory phrase (from W. Va. Code § 49-4-604(c)) means the court has found, based on the evidence, that the problems leading to the child’s removal are unlikely to be resolved in the near future. Factors include:

• History of noncompliance with services;
• Ongoing denial or minimization of the abuse or neglect;
• Professional assessments (e.g., psychological evaluations); and
• The child’s need for timely permanence and safety.

D. “No Less Restrictive Alternative”

Even if statutory grounds for termination are met, the court must consider whether a less drastic measure (like a continued improvement period, guardianship with relatives, or long-term foster care) can protect the child’s welfare.

If no such alternative can ensure safety and stability—because, for example, a parent continues to deny abuse and cannot be trusted to supervise contact—then termination is seen as the least restrictive means consistent with the child’s best interests.

E. “Meaningful Access” under the ADA

Under Title II of the ADA, public entities (including child welfare agencies and courts) must provide individuals with disabilities meaningful access to their programs and services. This often requires:

• Reasonable modifications to policies or procedures (e.g., more time for tasks, simplified language);
• Auxiliary aids and services (e.g., interpreters, written explanations); and
• Tailoring service delivery to the person’s functional limitations.

“Meaningful access” does not guarantee a favorable outcome. It means the person had a fair, disability-adjusted opportunity to participate and benefit from the services.

F. “Reasonable Accommodations” vs. “Outcome Guarantees”

A reasonable accommodation is an adjustment that helps a person with a disability use or benefit from a service on roughly equal terms with others, so long as it does not impose undue burdens or fundamentally alter the program.

The ADA does not:

• Require that reunification always succeed;
• Prevent courts from terminating parental rights when, after reasonable efforts with appropriate accommodations, the parent still cannot or will not protect the child.

The key question is whether disability—not the parent’s choices or other factors—caused an inability to access or benefit from the services offered.

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VII. Impact and Implications

A. For Child Welfare Agencies (DHS and Similar Entities)

In re M.V. underscores several practice points for DHS:

• Document identification and accommodation of disabilities.
  Even though the Court affirmed in this case, the record’s detail about the psychological evaluation and the psychologist’s modified service delivery was critical. Agencies should:
  • Assess for disabilities early;
  • Document the accommodations provided; and
  • Where a parent claims ADA protection, ensure that the family case plan explicitly addresses needed modifications.
• Distinguish disability-related limitations from willful noncompliance.
  The Court is clear that a parent’s choice to deny abuse is not protected by the ADA, especially when evidence shows they can understand the facts. Agencies should:
  • Work with professionals (psychologists, therapists) to clarify whether a parent’s behavior stems from cognitive limitations or from denial and values-based choices.
• Recognize the limits of services without acknowledgment.
  If a parent refuses to accept the child’s victimization or the dangerousness of the perpetrator, agencies and providers must realistically acknowledge that services may not achieve reunification and must plan permanency accordingly.

B. For Parents’ Counsel

The decision offers guidance to attorneys representing parents with disabilities:

• Raise ADA issues early and concretely.
  It is not enough to assert “I qualify under the ADA.” Counsel should:
  • Identify the client’s specific impairments (e.g., processing speed, reading comprehension);
  • Request specific accommodations (e.g., written summaries, simplified instructions, extended time); and
  • Build a record showing how the lack of those accommodations impeded the client’s progress.
• Confront the acknowledgment requirement directly.
  Where abuse or neglect involves denial (especially of sexual abuse), counsel must advise parents that:
  • Without acknowledgment, courts see the condition as untreatable; and
  • A purely defensive stance (“my child is lying”) is almost invariably fatal to reunification efforts.
• Distinguish between cognitive incapacity and emotional resistance.
  If a parent’s difficulties stem from mental illness or trauma rather than intellectual disability, those distinctions matter for:
  • What accommodations are appropriate; and
  • What treatment goals are realistic within statutory timelines.

C. For Trial Courts

In re M.V. implicitly encourages trial courts to:

• Make explicit findings on:
  • Whether the parent has a disability relevant to the case; and
  • Whether the parent’s failure to correct conditions is caused by the disability or by willful refusal.
• Ensure that providers explain the nature and extent of any accommodations used in service delivery.
• Weigh carefully the child’s expressed wishes, especially for older children, as part of the “welfare of the child” analysis.

D. For the Development of West Virginia Law

Although this is a memorandum decision rather than a full opinion with a syllabus, it contributes to the evolving jurisprudence by:

• Clarifying that W. Va. Code § 49-4-604(a)(1)’s ADA accommodation requirement focuses on meaningful access to services, not guaranteed reunification;
• Confirming that ADA-based claims will likely fail where:
  • Services have been reasonably modified; and
  • The core barrier to reunification is a parent’s denial of abuse, not their disability.
• Reinforcing the continued vitality of the acknowledgment doctrine in sexual abuse and failure-to-protect scenarios.

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VIII. Conclusion

In re M.V. stands at the intersection of disability rights and child protection. The case affirms that parents with disabilities are entitled to reasonable accommodations and meaningful access to reunification services under both the ADA and W. Va. Code § 49-4-604(a)(1). At the same time, it makes clear that:

• Accommodations are about access, not outcomes; and
• A parent’s persistent refusal to acknowledge a child’s sexual abuse—particularly when the parent is capable of understanding the evidence—can justify termination, regardless of intellectual limitations.

By upholding termination in these circumstances, the Supreme Court reinforces two core principles of West Virginia child welfare law:

1. The acknowledgment doctrine: abuse and neglect problems are “untreatable” if the parent refuses to acknowledge them or the perpetrator; and
2. The child’s right to safety and permanency prevails where, after reasonable efforts and accommodations, there is no reasonable likelihood that the parent will protect the child.

In practice, In re M.V. encourages agencies to thoughtfully accommodate disabilities while reminding all participants that the ultimate lodestar of these proceedings is the child’s safety, dignity, and long-term welfare.