State of West Virginia v. Aaron Anthony Edison, 16-0376

Background

Aaron A. Edison was named in a 2007 family‑court paternity/support action; he repeatedly missed three DNA test appointments and a noticed hearing. The family court in 2008 found him to be the child’s biological father, set past reimbursement support ($9,005.20) and ongoing support ($191.60/month), and found he had ability to pay. Edison appealed to the circuit court and lost; he did not appeal further, so the 2008 order became final.
In 2014 Edison was indicted criminally under W. Va. Code § 61‑5‑29(2) for felony failure to pay child support for that child. He moved to suppress unspecified documents/records and to quash the indictment.
Edison pursued a pro se civil petition (referenced in the record) and testified in 2014 that he had purportedly relinquished parental rights under the Safe Haven Act at the child’s birth and therefore owed no support; he also claimed he refused paternity testing to preserve anonymity under the Act.
The circuit court denied Edison’s motion to suppress and quash (Jan. 12, 2016). Edison entered a conditional plea to misdemeanor failure to pay support preserving his right to appeal the suppression/quash ruling; he was later sentenced to one year and ordered to pay restitution.
On appeal to the West Virginia Supreme Court of Appeals, Edison argued the Safe Haven Act applied to bar child‑support liability and that the circuit court erred in denying his suppression/quash motion. The Supreme Court affirmed.

Issues

Issue	Edison’s Argument	State’s Argument	Held
Whether the Safe Haven Act relieved Edison of parental/support obligations	Edison: He relinquished parental rights under the Safe Haven Act at the child’s birth and thus owes no support	State: The Act never applied because no hospital/health facility took custody; family‑court order establishing fatherhood and support is final	Held: Safe Haven Act did not apply; Edison may not use it to avoid support where he did not relinquish custody under the Act and a final order found him father and able to pay
Whether documents/records should be suppressed and indictment quashed (unspecified)	Edison: Suppression/quash appropriate (motion referenced unspecified records)	State: Circuit court properly denied motion; Edison did not identify or press specific suppression arguments on appeal	Held: Denial of the motion affirmed (Edison failed to identify records and did not press suppression on appeal)
Whether refusal to take paternity tests was justified by anonymity under Safe Haven Act	Edison: Refused tests to protect anonymity under the Act	State: Edison was not anonymous—hospital contacted him, he received proper notices and appealed, so anonymity claim meritless	Held: Court rejected anonymity defense; Edison had notice and opportunities for testing
Whether final family‑court order collaterally estops Edison from relitigating paternity/support	Edison: Contended Safe Haven defense could negate support obligation despite prior order	State: 2008 family‑court order became final; Edison cannot relitigate paternity/support now	Held: The 2008 final order controls; Edison cannot relitigate and avoid support obligations

Key Cases Cited

State v. Grimes, 226 W.Va. 411, 701 S.E.2d 449 (W. Va. 2009) (standard of review for motions to dismiss indictments and deference to circuit court fact‑findings)
In re K.H., 235 W.Va. 254, 773 S.E.2d 20 (W. Va. 2015) (use of initials to protect sensitive identities)
Melinda H. v. William R. II, 230 W.Va. 731, 742 S.E.2d 419 (W. Va. 2013) (same practice regarding initials)
State v. Brandon B., 218 W.Va. 324, 624 S.E.2d 761 (W. Va. 2005) (same practice regarding initials)
State v. Edward Charles L., 183 W.Va. 641, 398 S.E.2d 123 (W. Va. 1990) (same practice regarding initials)