In re Ta.C T.C., 237 A.3d 114

Child Ta.C. (b. 2016) was in sole custody of appellant (father) from Aug. 2017 until removal in Nov. 2018.
On Nov. 7, 2018 police found a homicide scene at the apartment where appellant and Ta.C. lived; roommate Eugene Johnson was dead, another occupant wounded, and the 2‑year‑old child asleep, uninjured but spattered with blood.
Appellant had left the child in Johnson’s care that morning; he invoked the Fifth in parts of the subsequent inquiry but later admitted marijuana use and said Johnson sold marijuana; police found an unsecured rifle and ammunition in the child’s bedroom closet but no drugs or paraphernalia in the apartment.
Evidence showed appellant’s history of substance abuse, hospitalizations, public intoxication incidents, and recent arrests (including for selling marijuana and unlawful handgun possession); the child had been regularly left with Johnson, whom appellant knew to be a drug dealer.
Magistrate found neglect under D.C. Code § 16-2301(9)(A)(ii), (iii), and (x); on appeal the court affirmed the finding under (ii) (without proper parental care or control), reversed (iii), and reversed the (x) finding (regular exposure to drug‑related activity in the home), but affirmed the overall neglect adjudication.

Issue	District's Argument	Appellant's Argument	Held
Whether evidence proved neglect under §16‑2301(9)(A)(x) ("regularly exposed to illegal drug‑related activity in the home")	Apartment occupants used and sold drugs; shooting likely drug‑related; unsecured firearm/ammo present, so child was regularly exposed	No evidence drugs or paraphernalia were used or sold in the apartment; drug activity was observed outside; finding rests on speculation	Reversed: insufficient evidence that illegal drug activity occurred or regularly exposed the child in the home
Whether evidence proved neglect under §16‑2301(9)(A)(ii) (child without proper parental care or control; substantial risk of serious harm)	Father’s substance abuse, leaving child with known drug dealer, unsecured firearm in child’s closet, and the roommate’s murder in the child’s presence created substantial risk	The adjudication improperly relies on a single incident (the homicide) and speculative links to drug activity	Affirmed: viewing the ‘‘entire mosaic’’ the court found a substantial risk of serious harm and thus neglect under §(ii)

In re De.S., 894 A.2d 448 (D.C. 2006) (upheld §(x) neglect where admissions, neighborhood complaints, paraphernalia, and firearm were found in the home)
In re A.H., 842 A.2d 674 (D.C. 2004) (trial court should assess more than a single "snapshot"; review is deferential to factfinder)
In re M.D., 758 A.2d 27 (D.C. 2000) (courts may consider the child’s broader history—the ‘‘entire mosaic’’—when assessing neglect)
In re L.H., 925 A.2d 579 (D.C. 2007) (reversed neglect finding where proof rested on speculation beyond a single incident)
In re K.M., 75 A.3d 224 (D.C. 2013) (§(ii) neglect can rest on a substantial risk of harm, not actual harm)
In re A.B., 999 A.2d 36 (D.C. 2010) (standard for reversing neglect findings: only if plainly wrong or without evidence)
Hicks v. United States, 697 A.2d 805 (D.C. 1997) (large sums of cash and contemporaneous drug evidence can be probative of constructive possession)