Judicial Discretion over Improvement Periods and Post‑Termination Contact in West Virginia Abuse and Neglect Cases: Commentary on In re N.M., B.M., C.M., P.M., A.H., and Z.H.

Judicial Discretion over Improvement Periods and Post‑Termination Contact in West Virginia Abuse and Neglect Cases: Commentary on In re N.M., B.M., C.M., P.M., A.H., and Z.H.

I. Introduction

This memorandum decision of the Supreme Court of Appeals of West Virginia, issued on November 25, 2025, in In re N.M., B.M., C.M., P.M., A.H., and Z.H. (No. 24‑718), addresses three interrelated issues in child abuse and neglect law:

  1. Whether a parent is entitled to a post‑dispositional improvement period after already having had a post‑adjudicatory improvement period.
  2. Whether the record supported termination of parental rights without using less restrictive alternatives.
  3. Whether the circuit court erred in disallowing post‑termination contact between the mother and her children.

The case arises from allegations that the petitioner mother, N.S., allowed her then‑boyfriend (later husband), D.S., to physically abuse her eleven‑year‑old child, N.M., and failed to protect the child. All six children—N.M., B.M., C.M., P.M., A.H., and Z.H.—were found to be abused and neglected due to residing in the same home at the time of the incident.

The Circuit Court of Harrison County terminated the petitioner’s parental, custodial, and guardianship rights and denied her request for post‑termination visitation. On appeal, the Supreme Court:

  • Affirmed the denial of a post‑dispositional improvement period;
  • Affirmed the termination of parental rights under West Virginia Code § 49‑4‑604(c)(6); and
  • Affirmed the denial of post‑termination contact under the pre‑existing Christina L. standard, while noting that new rule‑based standards (under amended Rule 15, as referenced in In re Z.D.-1) now exist going forward.

Although this is a memorandum decision (entered under Rule 21 of the Rules of Appellate Procedure), it provides a clear and instructive application of West Virginia’s statutory and case law framework governing:

  • Successive improvement periods;
  • The “no reasonable likelihood” standard for correcting abuse or neglect conditions; and
  • Post‑termination visitation and the role of children’s wishes in termination decisions.

II. Factual and Procedural Background

A. The Abuse and Neglect Petition

In November 2023, the West Virginia Department of Human Services (DHS) filed an abuse and neglect petition alleging that:

  • D.S., the petitioner’s then‑boyfriend, struck eleven‑year‑old N.M. across the face with an open hand, causing visible bruising.
  • The petitioner failed to protect N.M. from this physical abuse.
  • Because all six children resided in the same home during this incident, they were each alleged to be abused and neglected.

Shortly after the petition was filed, the petitioner and D.S. married.

B. Adjudication and Initial Improvement Period

In January 2024, the petitioner stipulated in writing that:

  • D.S. used inappropriate physical discipline on N.M.; and
  • She failed to protect N.M. from this abuse.

She further acknowledged that all other children lived in the home at the time, thereby admitting that they were “abused” in the statutory sense. Based on this stipulation, the circuit court:

  • Adjudicated the petitioner as an abusing parent; and
  • Declared each of the six children to be abused and neglected children.

In February 2024, the court granted the petitioner a post‑adjudicatory improvement period under West Virginia Code § 49‑4‑610. The conditions included:

  • Parental fitness evaluation and compliance with recommendations;
  • Regular drug screening;
  • Completion of parenting and life skills classes;
  • Supervised visitation and following all service‑provider guidelines;
  • Maintenance of a stable, clean, and substance‑free home;
  • Regular contact with DHS;
  • Individual and marital counseling; and
  • Psychiatric evaluation and compliance with recommendations.

C. Evaluations and Services

1. Parental Fitness Evaluation – Dr. Erin Teaff

In March 2024, Dr. Erin Teaff conducted a parental fitness evaluation and found:

  • The petitioner’s current capacity to parent safely was lacking—she did not then have the capacity to care for the children.
  • Her prognosis for improved parenting was only “fair”, contingent on significant therapeutic and behavioral changes.

Dr. Teaff recommended:

  • Individual, marital, and family therapy;
  • Strict adherence to prescribed mental‑health medications;
  • Parenting classes; and
  • Compliance with court directives as evidence of genuine commitment to change.

2. Psychiatric Evaluation – Dr. Alina Abascal

In June 2024, psychiatrist Dr. Alina Abascal evaluated the petitioner, diagnosing:

  • Major depressive disorder, recurrent;
  • Generalized anxiety disorder; and
  • Cluster B personality disorder (a category associated with emotional dysregulation and interpersonal instability).

Dr. Abascal recommended:

  • Dialectical Behavioral Therapy (DBT);
  • Cognitive Behavioral Therapy (CBT); and
  • Medication management as directed by a prescribing physician.

Crucially, the Supreme Court notes that the petitioner refused to sign a medical release, delaying the issuance of Dr. Abascal’s written report—a behavior that the Court later views as non‑cooperation with services.

D. Compliance Problems During the Improvement Period

Evidence at the October 2024 dispositional hearing revealed pervasive non‑compliance:

  • Therapy non‑compliance:
    • Dr. Don Worth, providing individual and marital counseling, testified that the petitioner missed several appointments and ceased contact after May 2024.
    • He concluded she failed to complete both individual and marital counseling.
  • Drug screening failures:
    • A Harrison County Day Report employee reported that the petitioner missed five scheduled drug screens.
  • Anger management non‑completion:
    • A Community Corrections employee testified that she failed to complete anger management classes.
  • Visitation and contact issues:
    • She had unpermitted contact with N.M. and made further attempts at impermissible contact.
    • Child Protective Services reported that she and D.S. drove around a DHS building yelling obscenities at one of the fathers, leading the court to impose “strict visitation guidelines” that she then violated.
    • She had not visited the children since April 2024 and informed a visitation supervisor in September 2024 that she no longer wished to attend visits.
  • Housing and honesty issues:
    • The petitioner admitted she failed to maintain stable housing.
    • She failed to notify DHS when she moved out of state and later returned.
    • She was found to be untruthful with DHS and service providers.
  • Harassment and confidentiality breaches:
    • A non‑abusing father reported that the petitioner breached confidentiality rules by posting case details on a crowdfunding platform and social media.
    • The court formally warned her to stop sharing case details.
    • The petitioner was found to have harassed foster parents and disrupted placements.

E. Disposition in the Circuit Court

Based on the evidence, the circuit court concluded:

  • The petitioner had not successfully completed the post‑adjudicatory improvement period.
  • She failed to follow key recommendations from the parental fitness and psychiatric evaluations.
  • There was no reasonable likelihood that the conditions of abuse and neglect could be substantially corrected in the near future.
  • Termination of parental, custodial, and guardianship rights was necessary for the children’s welfare so they could achieve permanency (with adoption in the current placements as the permanency plan).
  • Because of the petitioner’s harassment of caregivers, inability to respect visitation rules, and her own stated disengagement from visits, post‑termination contact would not be in the children’s best interests and would risk interfering with their permanent placements.

The circuit court therefore:

  • Denied a post‑dispositional improvement period;
  • Terminated all of the petitioner’s parental, custodial, and guardianship rights; and
  • Denied any post‑termination visitation or contact with the children.

The petitioner appealed these determinations to the Supreme Court of Appeals.

III. Summary of the Supreme Court’s Opinion

The Supreme Court, reviewing the circuit court’s decision under the standard set forth in Syllabus Point 1 of In re Cecil T., 228 W. Va. 89, 717 S.E.2d 873 (2011), held:

  1. No error in denying a post‑dispositional improvement period. Because the petitioner did not substantially comply with her existing improvement period, she could not demonstrate the “substantial change in circumstances” and likelihood of full participation required by West Virginia Code § 49‑4‑610(3)(D).
  2. No error in terminating parental rights. The evidence established that there was no reasonable likelihood
  3. No error in denying post‑termination contact. Applying Syllabus Point 5 of In re Christina L., 194 W. Va. 446, 460 S.E.2d 692 (1995), and State ex rel. Amy M. v. Kaufman, 196 W. Va. 251, 470 S.E.2d 205 (1996), the Court held that the petitioner’s conduct—harassing foster parents, violating visitation rules, and expressing disinterest in visits—demonstrated that contact would not be in the children’s best interests and would unreasonably interfere with their permanent placement.

The Court also rejected an ancillary argument that the circuit court was required to consider the children’s wishes regarding termination. It held that West Virginia Code § 49‑4‑604(c)(6)(C) requires consideration of a child’s wishes only if the child is:

  • Fourteen or older, or
  • “Otherwise of an age of discretion” as found by the court.

Because these children were all under fourteen and the circuit court had made no finding that any were otherwise of an age of discretion, it was not required to consider their wishes, and the challenge failed.

The judgment of the circuit court was therefore affirmed in its entirety.

IV. Detailed Analysis

A. Standard of Review and Its Significance

The Court begins by reaffirming the standard stated in Syllabus Point 1 of In re Cecil T.:

On appeal from a final order in an abuse and neglect proceeding, findings of fact are reviewed under a clearly erroneous standard, while conclusions of law are reviewed de novo.

This dichotomy matters because many of the mother’s arguments—particularly those about compliance, capacity to improve, and the children’s best interests—hinge on contested facts. Under the clearly erroneous standard, the Supreme Court:

  • Does not re‑weigh evidence or second‑guess credibility determinations, and
  • Will only disturb the circuit court’s factual findings if left with a “definite and firm conviction that a mistake has been committed.”

Given the robust evidentiary record of non‑compliance and disruptive behavior, it was unlikely that the Supreme Court would find clear error, and this heavily shaped the outcome.

B. Denial of a Post‑Dispositional Improvement Period

1. Statutory Framework: West Virginia Code § 49‑4‑610(3)(D)

A key statutory provision is West Virginia Code § 49‑4‑610(3)(D), which governs post‑dispositional improvement periods when the parent has already received a prior improvement period:

To obtain a post‑dispositional improvement period in those circumstances, the parent must demonstrate that since the initial improvement period, they have experienced a substantial change in circumstances and that they are now likely to fully participate.

This requirement prevents repetitive or open‑ended improvement periods when a parent has not truly changed. It transforms the burden into a forward‑looking inquiry informed by the parent’s past performance:

  • Has anything genuinely changed since the last improvement period?
  • Has the parent demonstrated a reliable pattern of participation?

2. Discretion of the Circuit Court – In re Tonjia M.

The Court cites In re Tonjia M., 212 W. Va. 443, 573 S.E.2d 354 (2002), to underscore judicial discretion:

"The circuit court has the discretion to refuse to grant an improvement period when no improvement is likely."

This principle gives the trial court broad authority to:

  • Evaluate sincerity and consistency of the parent’s efforts;
  • Weigh expert recommendations against the parent’s actual follow‑through; and
  • Denounce “token” or sporadic compliance when, in substance, the parent has not changed.

3. Application to the Petitioner’s Conduct

The Supreme Court emphasized the following factual findings by the circuit court:

  • Drug screens: Multiple missed tests, which courts may treat as equivalent to positive tests or at minimum as non‑compliance.
  • Counseling: Non‑completion of individual and marital counseling, despite clear recommendations from both evaluators.
  • Recommendations ignored: Failure to meaningfully follow the parental fitness and psychiatric recommendations (e.g., therapy modalities and medication compliance).
  • Housing and employment: Lack of stable housing and employment; failure to keep DHS informed about interstate moves.
  • Visitation: Abrupt discontinuation of visits, including a statement to a visitation supervisor that she no longer wanted visits.
  • Rule violations and dishonesty: Disrespect for service providers, harassment of placements, unpermitted contact with a child, and untruthfulness with DHS and service providers.

Taken together, these facts led the Court to conclude that the petitioner:

  • Did not substantially comply with her existing improvement period; and
  • Failed to show any substantial change in circumstances that would justify a new, post‑dispositional improvement period.

Given § 49‑4‑610(3)(D) and Tonjia M., the Supreme Court held there was no abuse of discretion in denying another improvement period.

C. Termination of Parental Rights

1. Termination Standard – West Virginia Code § 49‑4‑604(c)(6) and (d)

The statutory basis for termination was West Virginia Code § 49‑4‑604(c)(6), which allows termination when:

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

Section 49‑4‑604(d) elaborates on what “no reasonable likelihood” means. It includes situations where the parent has:

“demonstrated an inadequate capacity to solve the problems of abuse or neglect on their own or with help.”

This language is critical: even when services are offered, the focus is on whether the parent actually develops the ability to protect and parent safely.

2. Linking Termination to Failure in the Improvement Period

The Court anchors its reasoning in two key precedents:

  • In re Kristin Y., 227 W. Va. 558, 712 S.E.2d 55 (2011) (Syllabus Point 5 in part, quoting In re R.J.M., 164 W. Va. 496, 266 S.E.2d 114 (1980)):
    Termination of parental rights may be used without resort to less restrictive alternatives when there is no reasonable likelihood that the conditions of neglect or abuse can be substantially corrected under § 49‑4‑604(c)(6) and termination is necessary for the child’s welfare.
  • In re K.L., 247 W. Va. 657, 885 S.E.2d 595 (2022):
    A parent’s failure to participate in their improvement period is a statutorily recognized basis upon which the Court regularly affirms termination of parental rights.

By invoking these cases, the Court makes two interlocking points:

  1. Failure to engage with services is itself strong evidence that the underlying problems cannot be corrected in the near future.
  2. In such circumstances, the court is not required to try less restrictive dispositional alternatives (like guardianship or temporary custody with continued contact) before terminating rights.

3. Role of Visitation and Parental Engagement – In re Katie S.

The Court cites In re Katie S., 198 W. Va. 79, 479 S.E.2d 589 (1996), which noted in footnote 14:

A parent’s lack of interest in visiting their children is a significant factor in determining their potential to improve sufficiently and achieve minimum standards to parent.

Here, the petitioner:

  • Stopped visiting as of April 2024; and
  • Told a visitation supervisor in September 2024 that she no longer wished to attend visits.

This non‑engagement was treated as a stark indicator of:

  • Lack of motivation to reunify;
  • Weak or eroding bonds with the children; and
  • An overall pattern inconsistent with achieving safe parenting in the foreseeable future.

4. Children’s Best Interests and Permanency

The Court emphasizes that termination was necessary to allow the children to achieve permanency via adoption in their current placements. This reflects a consistent theme in abuse and neglect jurisprudence:

  • Children are entitled to stability and finality, not indefinite uncertainty.
  • Where a parent demonstrates persistent non‑compliance and disruptive behavior, extending the case often harms children’s emotional and developmental well‑being.

Therefore, the Court concluded that both statutory prongs were met:

  1. No reasonable likelihood of substantial correction of the abusive/neglectful conditions in the near future; and
  2. Termination necessary for the children’s welfare, particularly their need for permanency.

D. Denial of Post‑Termination Contact (Visitation)

1. Pre‑2025 Standards – In re Christina L. and State ex rel. Amy M. v. Kaufman

The Court applied Syllabus Point 5 of In re Christina L., 194 W. Va. 446, 460 S.E.2d 692 (1995):

When parental rights are terminated due to neglect or abuse, the circuit court may nevertheless in appropriate cases consider whether continued visitation or other contact with the abusing parent is in the best interest of the child. The circuit court should consider, among other things:
  • whether a close emotional bond has been established between parent and child;
  • the child’s wishes, if of sufficient maturity; and
  • whether visitation would be not detrimental and indeed in the child’s best interest.

The Court also cites State ex rel. Amy M. v. Kaufman, 196 W. Va. 251, 470 S.E.2d 205 (1996), which stressed:

Post‑termination contact should not unreasonably interfere with the child’s permanent placement.

Together, these cases frame post‑termination visitation as:

  • Discretionary, not automatic—even when some bond exists;
  • Dependent on both the child’s welfare and the stability of the placement; and
  • Subject to being denied if the parent’s behavior undercuts the child’s stability or safety.

2. The Court’s Reliance on Parental Conduct

The petitioner argued that:

  • She had a significant emotional bond with the children; and
  • The children desired continuing contact.

However, the Court emphasized contrary evidence:

  • The petitioner told a visitation supervisor she did not want further visits during the proceedings.
  • She harassed foster parents and disrupted placements.
  • She repeatedly violated visitation rules and had unpermitted contact with N.M.

On this record, the Supreme Court concluded:

  • Continued contact was not in the children’s best interests because it undermined placement stability and emotional security.
  • Permitting any post‑termination contact would unreasonably interfere with the children’s permanent placements, contrary to Amy M.

Accordingly, the denial of post‑termination visitation and contact was affirmed.

3. Transition to New Standards – In re Z.D.-1 and Rule 15

Notably, the Court includes a forward‑looking footnote referencing In re Z.D.-1, 251 W. Va. 743, 916 S.E.2d 375 (2025). It explains that:

  • After the circuit court’s order in this case, the Supreme Court provisionally amended Rule 15 of the West Virginia Rules of Procedure for Child Abuse and Neglect Proceedings.
  • Those amendments adopt “appropriate standards for consideration of post‑termination visitation outside of a fact‑based context”—i.e., standards now codified in a rule rather than solely developed case by case.

However, the Court is clear that:

  • It applies the pre‑amendment standards (essentially the Christina L. framework) because that was the law at the time of the circuit court’s order.
  • The new Rule 15 standards govern cases going forward and are not retroactively imposed on this case.

This underscores a principle of prospective application for new procedural rules affecting post‑termination visitation standards.

E. Children’s Wishes and Age of Discretion – § 49‑4‑604(c)(6)(C)

The petitioner contended that the circuit court erred by not considering the children’s wishes regarding termination. The Supreme Court rebuffed this by closely parsing West Virginia Code § 49‑4‑604(c)(6)(C), which requires the court to:

give consideration to the wishes of a child 14 years of age or older or otherwise of an age of discretion as determined by the court.

Key points in the Court’s analysis:

  • All of the children were under fourteen at the time of disposition.
  • The circuit court made no specific findings that any child was “otherwise of an age of discretion.”
  • Absent such age or findings, the court was not statutorily required to consider their wishes about termination.

This is an important clarification:

  • Children’s wishes are mandatory considerations only when statutory age or discretion criteria are met.
  • Otherwise, while courts may consider such wishes as part of a general best‑interests analysis, they are not bound to do so.

V. Simplifying Key Legal Concepts

1. “Improvement Period”

An improvement period is a structured period during which a parent is given a formal opportunity—under court supervision and DHS oversight—to correct conditions that led to abuse or neglect findings. It typically involves:

  • Therapy and counseling;
  • Substance abuse treatment and testing;
  • Parenting classes and skills training;
  • Visitation with the children; and
  • Compliance with specific court‑ordered conditions.

West Virginia law provides for various types (pre‑adjudicatory, post‑adjudicatory, and post‑dispositional), but a second or subsequent improvement period requires a showing of substantial change and a likelihood of full compliance.

2. “No Reasonable Likelihood of Substantial Correction”

This phrase, used in West Virginia Code § 49‑4‑604(c)(6) and (d), means:

  • The court believes, based on evidence, that the parent is unlikely to fix the main problems that caused the abuse or neglect;
  • Even with the help offered (services, counseling, etc.), the parent has shown an inadequate capacity to solve those problems; and
  • This is evaluated in the near future, not in some indefinite or speculative long term.

3. Post‑Termination Visitation / Contact

After parental rights are terminated, there is no automatic right to continued visitation or contact. Historically under Christina L.:

  • The circuit court could allow contact if:
    • There was a strong emotional bond;
    • The child wished contact and was mature enough to express that preference; and
    • Contact was not harmful and was in the child’s best interests.
  • The court also had to ensure that contact would not undermine permanent placement, per Amy M.

Now, as the Court notes, new standards for post‑termination visitation have been incorporated into Rule 15 (as referenced in In re Z.D.-1), but the basic concepts of best interests and non‑interference with permanency remain central.

4. “Age of Discretion” and Children’s Wishes

Under § 49‑4‑604(c)(6)(C):

  • A child 14 or older has a statutory right for their wishes regarding termination to be considered.
  • A younger child can have this right if the court finds they are “otherwise of an age of discretion”—that is, mature enough to understand the nature and consequences of the termination decision.

If neither applies, the court need not consider the child’s wishes, though it remains free to do so as one factor among many in a broader best‑interests analysis.

5. “Memorandum Decision” Under Rule 21

This case was resolved through a memorandum decision pursuant to Rule 21 of the West Virginia Rules of Appellate Procedure, which allows the Court to affirm without oral argument when:

  • The decisional process would not be significantly aided by oral argument; and
  • The case can be resolved by clear application of existing law.

Although typically more concise and fact‑specific than full opinions, memorandum decisions still reflect the Court’s contemporary application of governing statutes and precedents, and they can be highly instructive for lower courts and practitioners.

VI. Impact and Broader Significance

A. Reinforcement of Strict Standards for Successive Improvement Periods

This decision reinforces that:

  • Parents do not have an entitlement to multiple improvement periods.
  • Circuit courts enjoy substantial discretion to deny a post‑dispositional improvement period when:
    • A parent fails to substantially comply with an existing improvement period; and
    • The parent cannot show a substantial change in circumstances making future full participation likely.

Future litigants should expect that:

  • Spotty or inconsistent compliance will be treated as non‑compliance rather than partial success.
  • A pattern of missed services, dishonesty, or rule‑breaking will weigh heavily against granting any additional improvement period.

B. Emphasis on Active Participation and Visitation as Predictors of Reunification

The Court’s reliance on Katie S. and K.L. highlights:

  • Active, sustained participation in services and visitation is a key indicator that reunification may be realistic.
  • Conversely, withdrawal from visits and disengagement from services is seen as powerful evidence that the parent will not meet minimum parenting standards in the near future.

Practically, this signals that:

  • Parents must maintain consistent visitation absent extraordinary circumstances.
  • Expressing disinterest in visits or openly withdrawing during the case will likely be dispositive on the issue of termination.

C. Continued Deference to Placement Stability and Caregiver Protection

The decision strongly protects:

  • Foster and kinship placements against parental harassment and interference; and
  • The children’s need for stable, calm, and unthreatened homes.

The Court’s approach signals that where a parent:

  • Harasses caregivers;
  • Violates no‑contact or visitation rules; or
  • Uses social media or public platforms to undermine confidentiality or placements,

courts are justified in:

  • Imposing strict visitation conditions during the case;
  • Terminating visitation when non‑compliance persists; and
  • Denying post‑termination contact to protect permanency and caregiver stability.

D. Clarification of When Children’s Wishes Must Be Considered

By explicitly relying on § 49‑4‑604(c)(6)(C), the Court clarifies:

  • Children’s wishes regarding termination must be considered only when the statutory criteria are met (14+ or otherwise found to be of an age of discretion).
  • During dispositional litigation, advocates on both sides should be prepared to:
    • Establish or contest a finding that a younger child is of an “age of discretion,” and
    • Present evidence about the maturity and understanding of the child if such a finding is sought.

E. Transitional Significance for Post‑Termination Visitation Law

The Court’s reference to In re Z.D.-1 and amendments to Rule 15 signals a doctrinal shift:

  • Previously, post‑termination visitation was governed primarily by Christina L. and Amy M., as case law standards.
  • Now, the Court has adopted rule‑based standards to guide post‑termination visitation decisions in a more uniform way.
  • In re N.M., B.M., C.M., P.M., A.H., and Z.H. stands as one of the last decisions primarily applying the pre‑Rule‑15 framework while acknowledging the transition.

Future cases will likely explore and elaborate on the practical application of amended Rule 15, but the core principles highlighted here—best interests and non‑interference with permanency—are almost certain to remain central.

VII. Conclusion

In re N.M., B.M., C.M., P.M., A.H., and Z.H. offers a clear, structured reaffirmation of several important principles in West Virginia abuse and neglect law:

  • Improvement periods are opportunities, not entitlements. When a parent fails to comply meaningfully, courts may—and often should—decline to grant additional improvement periods.
  • Termination of parental rights is justified, without less restrictive alternatives, when there is no reasonable likelihood that conditions can be corrected in the near future and when termination is necessary for children’s welfare and permanency.
  • Post‑termination contact remains a discretionary remedy. It may be denied where the parent’s conduct threatens placement stability or where the parent has disengaged from the relationship or process.
  • Children’s wishes regarding termination must be considered only when the statutory criteria on age and maturity are met.
  • The decision sits at a doctrinal crossroads, applying the older Christina L. standard while acknowledging that new, rule‑based standards (under amended Rule 15, as referenced in In re Z.D.-1) will shape future post‑termination visitation questions.

As a memorandum decision, this case may not be as broadly precedential as a full opinion, but it is highly instructive for practitioners and courts in understanding:

  • How non‑compliance with services and visitation is evaluated;
  • How the “no reasonable likelihood” standard is applied in termination cases; and
  • How and when courts may properly decline both additional improvement periods and post‑termination contact to protect children’s best interests and permanency.

Case Details

Year: 2025
Court: Supreme Court of West Virginia

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