In Re: P.L. and A.W., 16-0649

DHHR filed abuse and neglect petition (Sept 2015) after reports the mother, J.L., and her two young children were living in a tent, the children showed injuries/poor health, and J.L. admitted current and recent opioid use and prostitution to support addiction.
Children were removed and an adjudicatory hearing (Oct 2015) found J.L. an abusing parent; the court granted a post-adjudicatory improvement period focused on substance-abuse treatment.
J.L. entered a detox program but left before completing treatment, later left a second program, and was unreachable for extended periods; DHHR filed to terminate parental rights (Apr 2016).
At disposition (May 2016) service providers testified J.L. voluntarily exited treatment, failed to properly parent during supervised visits, and was not reliably contactable; J.L. could not produce a drug-screen sample when ordered.
The circuit court adopted the guardian’s report and terminated J.L.’s parental rights (June 1, 2016); J.L. appealed arguing insufficient factual findings in the dispositional order and that she was entitled to an additional improvement period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the dispositional order lacked the required findings of fact and conclusions of law	J.L.: circuit court failed to make adequate written findings at disposition, warranting reversal	State/DHHR: record contained ample evidence supporting termination; any omission did not substantially frustrate required process	Court: No reversible error; although Rule 36 and §49-4-604 require findings, the record sufficiently supports termination and omission did not require vacatur
Whether J.L. was entitled to an extension or an additional improvement period	J.L.: she substantially complied with her improvement period (acknowledgement, attendance) and thus deserved more time or a new improvement period	State/DHHR: J.L. did not substantially comply—she quit two programs, resumed substance use, was unreachable, and failed a court-ordered drug screen; she showed no substantial change since the initial period	Court: Denied. J.L. failed to make sufficient improvement and did not show a substantial change in circumstances required to grant an additional or extended improvement period

In Interest of Tiffany Marie S., 196 W.Va. 223, 470 S.E.2d 177 (W. Va. 1996) (standard of review for circuit-court factfinding in abuse and neglect cases)
In re Cecil T., 228 W.Va. 89, 717 S.E.2d 873 (W. Va. 2011) (articulating appellate review principles for family-law findings)
In re Edward B., 210 W.Va. 621, 558 S.E.2d 620 (W. Va. 2001) (disposition orders must comply with rules and statutes; failure may require vacatur)
In re Emily G., 224 W.Va. 390, 686 S.E.2d 41 (W. Va. 2009) (procedural compliance required but relief depends on whether substantial disregard occurred)
In the Interest of Carlita B., 185 W.Va. 613, 408 S.E.2d 365 (W. Va. 1991) (court’s review of improvement-period performance at period’s end)
In re Faith C., 226 W.Va. 188, 699 S.E.2d 730 (W. Va. 2010) (standards for evaluating whether a parent satisfied improvement-period goals)