In Re: I.J.-1, I.J.-2, and T.J., 16-1005

In October 2013 the DHHR filed abuse and neglect proceedings after alleging the children’s father, J.J., sexually abused a child; the mother (petitioner R.J., now R.C.) was designated a non‑offending parent.
The circuit court adjudicated J.J. as an abusive and neglectful parent after adjudicatory hearings.
In 2016 J.J. voluntarily relinquished his parental rights; the circuit court accepted the relinquishment and terminated his parental rights by order dated September 9, 2016.
The circuit court denied petitioner’s motion to award child support from J.J. but provided no explanation for that denial.
Petitioner appealed only the denial of child support; DHHR and the children’s guardian ad litem supported petitioner’s appeal.
The Supreme Court of Appeals affirmed the termination of parental rights but reversed and remanded the child‑support ruling, directing the circuit court to address child support consistent with In re Ryan B.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred in denying child support after J.J.’s voluntary relinquishment of parental rights	R.J.: court should require J.J. to pay child support under the Guidelines following termination	Circuit court: denied child support (no on‑record justification provided)	Court: termination affirmed; denial of child support reversed and remanded — circuit court must apply In re Ryan B. and either order support under Guidelines or make an on‑record finding explaining a rare exception

In re Ryan B., 224 W.Va. 461, 686 S.E.2d 601 (W. Va. 2009) (holding terminated parents ordinarily must continue paying child support and courts must explain any rare deviation)
In re Cecil T., 228 W.Va. 89, 717 S.E.2d 873 (W. Va. 2011) (standard of review for abuse and neglect findings)
In Interest of Tiffany Marie S., 196 W.Va. 223, 470 S.E.2d 177 (W. Va. 1996) (standard on appellate review of circuit court findings)