In Re: J.F., L.F., and A.F., 16-0851

DHHR filed abuse and neglect petition (Sept 2015) alleging filthy home, chronic untreated head lice, insufficient food, mother's overmedication, and that eldest child (J.F.) was forced to care for siblings and emotionally blamed for CPS involvement.
Petitioner father (G.F.) admitted neglect and medical neglect at adjudication but contested physical abuse; the court found physical abuse.
Parents were granted post-adjudicatory improvement periods (Nov 2015). DHHR later moved to terminate both improvement periods and parental rights (Mar 2016).
Evidence at hearings: therapist said parents made no progress due to denial/lack of insight; in‑home provider said some change but conditions unsafe; psychologist diagnosed petitioner with personality disorder with antisocial traits and concluded prognosis for improved parenting was nonexistent.
Circuit court terminated the parents’ improvement periods (June 2016) and parental rights (Aug 1, 2016), finding continued denial of abuse/neglect; father appealed arguing he was entitled to an extension of his improvement period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred in denying an extension of father’s post‑adjudicatory improvement period	Father: he substantially complied with improvement terms (in‑home provider testimony of some change) and needed additional therapy, so a 3‑month extension was warranted	DHHR/court: father failed to acknowledge abuse/neglect, made no therapeutic progress, and children would remain at risk; extension would be futile	Court: Affirmed — extension denied because father lacked substantial compliance and failed to acknowledge problems, preventing meaningful progress

In Interest of Tiffany Marie S., 196 W.Va. 223, 470 S.E.2d 177 (W. Va. 1996) (standard of review for circuit‑court findings in abuse and neglect cases)
In re Cecil T., 228 W.Va. 89, 717 S.E.2d 873 (W. Va. 2011) (reiterating standard of review)
In re Timber M., 231 W.Va. 44, 743 S.E.2d 352 (W. Va. 2013) (failure to acknowledge abuse/neglect makes improvement period futile)
In re Charity H., 215 W.Va. 208, 599 S.E.2d 631 (W. Va. 2004) (same principle regarding acknowledgement as prerequisite to treatment)
Michael D.C. v. Wanda L.C., 201 W.Va. 381, 497 S.E.2d 531 (W. Va. 1997) (deference to factfinder on witness credibility)