Rayonda Richards v. Alexandria Department of Community & Human Services, 1702164

Mother (Rayonda Richards) had a long history (since 2008) of substance abuse, unstable housing, and mental health concerns; prior juvenile court orders required evaluations and services.
In 2015–2016 five children were removed after findings of abuse/neglect, positive drug screens, missed medical care, and an incident of domestic violence; mother was convicted for abducting children in 2015.
The Alexandria Department of Community & Human Services (the Department) provided services: parenting coaching, referrals to the Community Services Board for substance abuse and mental-health treatment, and a court-ordered psychological evaluation.
Psychologist Dr. Mansaray found mother posed a moderate risk for future neglect and recommended individual therapy, parenting coaching, DBT group, and family therapy. Mother largely rejected the findings, attended few therapy sessions, and did not engage consistently in substance-abuse treatment.
The JDR court terminated mother’s parental rights and set adoption goals; the circuit court affirmed termination under Va. Code § 16.1‑283(C)(2), finding mother unable (not unwilling) to remedy the conditions despite services.

Issue	Plaintiff's Argument (Richards)	Defendant's Argument (Department)	Held
Whether mother substantially remedied conditions leading to foster care within 12 months	Richards: had stable housing/employment, appropriate visits, no longer with fathers — therefore substantially remedied conditions	Department: mother failed to remedy longstanding substance‑use and mental‑health problems and denied need for therapy	Court: No — mother did not remedy or acknowledge core conditions; termination affirmed
Whether Department provided reasonable and appropriate services	Richards: Department knew mother had limited capacity and failed to adequately explain services orally or tailor assistance	Department: Provided parenting coach, counseling referrals, psychological evaluation, and repeated encouragement; mother failed to engage	Court: Services were reasonable and appropriate given case circumstances; failure to progress was mother’s refusal/noncompliance
Whether mother was denied due process by Department’s inaction	Richards: inability to remedy was due to Department’s insufficient efforts, violating due process	Department: Provided procedural protections, opportunity to present evidence, and delivered services; state has duty to protect children	Court: No due process violation; mother had counsel, hearings, chance to cross‑examine and present evidence; termination constitutional

Martin v. Pittsylvania Cty. Dep’t of Soc. Servs., 3 Va. App. 15 (1986) (trial court’s ore tenus findings entitled to great weight)
Logan v. Fairfax Cty. Dep’t of Human Dev., 13 Va. App. 123 (1991) (child’s best interests paramount; Department not required to force services on an unwilling parent)
Ferguson v. Stafford Cty. Dep’t of Soc. Servs., 14 Va. App. 333 (1992) (reasonableness of Department efforts judged by case circumstances)