In Re: B.P. and O.P., 17-0334

DHHR filed abuse-and-neglect petition (Feb 2016) after newborn O.P. tested positive for amphetamines and was allegedly abandoned at the hospital; parents accused of substance abuse-related neglect.
Petitioner (father J.P.) stipulated at adjudication (July 2016) to neglect based on substantial absence and failure to provide; court granted a post-adjudicatory improvement period.
DHHR moved to revoke petitioner’s improvement period for failure to engage in services, drug screens, visits, and contact; hearing held in Dec 2016 (petitioner absent, represented by counsel).
Circuit court revoked the improvement period based on service-provider testimony of noncompliance.
At disposition (Mar 2017) petitioner admitted failing to attend offered inpatient treatment, visiting the children only once in the year, and completing only one parenting class; court found no progress and terminated his parental rights.
On appeal petitioner argued the court erred in revoking the improvement period and terminating parental rights; appellate brief failed to cite authority or adequate record references, so the Supreme Court declined to address the substantive assignments and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred in terminating petitioner’s improvement period	Petitioner contended revocation was improper (brief lacks developed argument or citations)	DHHR argued petitioner failed to participate in required services and contacts	Court: did not reach substance because petitioner’s appellate brief failed to comply with Rule 10(c)(7); affirmed lower court’s revocation implicitly upheld
Whether the circuit court erred in terminating petitioner’s parental rights	Petitioner asserted termination was erroneous (no cited legal support)	DHHR and guardian argued petitioner made no progress (failed treatment, minimal visits, limited parenting classes)	Court: affirmed termination; declined to address merits due to inadequate appellate briefing, finding no reversible error
Whether appellate briefing deficiencies warrant disregarding assignments of error	Petitioner’s brief offered no proper citations or record references; attempted one unclear case citation	State relied on appellate rules and administrative order requiring authority and record citations	Court: enforced Rule 10(c)(7) and its administrative order; refused to consider inadequately briefed issues and affirmed

In Interest of Tiffany Marie S., 196 W.Va. 223, 470 S.E.2d 177 (1996) (standard of review for bench-tried abuse-and-neglect cases; findings of fact reviewed for clear error)
In re Cecil T., 228 W.Va. 89, 717 S.E.2d 873 (2011) (restating appellate review standard and application in child welfare matters)