Father objection in Virginia

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2019“Generally, the admissibility of evidence ‘is within the broad discretion of the trial court, and an [evidentiary] ruling will not be disturbed on appeal in the absence of an abuse of 4 Father’s objection to the line of questioning was noted in his objections attached to the final order. -8- discretion.’” Surles v. Mayer, 48 Va. App. 146, 177 (2006) (quoting Blain v. Commonwealth, 7 Va. App. 10, 16 (1988)) (brackets in original); see also Castillo, 68 Va. App. at 558 .

2025The United States is a contracting party of the Hague Convention, which “was adopted in 1980 in response to the problem of international child abductions during domestic disputes.” Golan v. Saada, 596 U.S. 666, 670 (2022) (quoting Abbott v. Abbott, 560 U.S. 1, 8 (2010)).

2024The United States is a contracting party of the Hague Convention, which “was adopted in 1980 in response to the problem of international child abductions during domestic disputes.” Golan v. Saada, 596 U.S. 666 , 670 (2022) (quoting Abbott v. Abbott, 560 U.S. 1, 8 (2010)).

2025The United States is a contracting party of the Hague Convention, which “was adopted in 1980 in response to the problem of international child abductions during domestic disputes.” Golan v. Saada, 596 U.S. 666, 670 (2022) (quoting Abbott v. Abbott, 560 U.S. 1, 8 (2010)).

2024The United States is a contracting party of the Hague Convention, which “was adopted in 1980 in response to the problem of international child abductions during domestic disputes.” Golan v. Saada, 596 U.S. 666 , 670 (2022) (quoting Abbott v. Abbott, 560 U.S. 1, 8 (2010)).

2001He was entitled to challenge it because an order of adoption is void when "personal jurisdiction over [the natural parent] was lacking at the time of the entry of the final order of adoption." Carlton v. Paxton, 14 Va.App. 105, 114 , 415 S.E.2d 600, 605 (1992).

2001He was entitled to challenge it because an order of adoption is void when “personal jurisdiction over [the natural parent] was lacking at the time of the entry of the final order of adoption.” Carlton v. Paxton, 14 Va.App. 105, 114 , 415 S.E.2d 600, 605 (1992).

2020Specifically, he argues that the trial court “abused its discretion by not granting the Father a hearing based on the material change of circumstances stemming from [A.S.] walking out of the Mother’s home and refusing to live there,” an incident that occurred on March 11, 2019. - 12 - Once a trial court renders a child custody decision, Code § 20-108 allows the court to “revise and alter such decree concerning the care, custody, and maintenance of the children . . . as the circumstances of the parents and the benefit of the children may require.” “In determining whether a change in custody is

2020Specifically, he argues that the trial court “abused its discretion by not granting the Father a hearing based on the material change of circumstances stemming from [A.S.] walking out of the Mother’s home and refusing to live there,” an incident that occurred on March 11, 2019. - 12 - Once a trial court renders a child custody decision, Code § 20-108 allows the court to “revise and alter such decree concerning the care, custody, and maintenance of the children . . . as the circumstances of the parents and the benefit of the children may require.” “In determining whether a change in custody is

2020As our Supreme Court has explained, “The second prong of the test is in accord with the countless cases in which we have stated that the best interests of the children are paramount,” and is therefore “clearly the most important part of the two-part test.” Keel v. Keel, 225 Va. 606, 612 (1983).

2019Steinberg filed an appeal to this Court, in which he argues the circuit court erred when it refused to allow him “to put on any independent evidence regarding the alleged abuse and neglect allegations at trial” and erred in granting father’s “motion to dismiss due to the fact that [ADCHS] stated it would not present any evidence for its case at trial.” ANALYSIS “It is well-settled that a party who challenges the ruling of a lower court must on appeal assign error to each articulated basis for that ruling.” Ferguson v. Stokes, 287 Va. 446 , 452 (2014) (quoting Manchester Oaks Homeowners Ass’n v

2019Steinberg filed an appeal to this Court, in which he argues the circuit court erred when it refused to allow him “to put on any independent evidence regarding the alleged abuse and neglect allegations at trial” and erred in granting father’s “motion to dismiss due to the fact that [ADCHS] stated it would not present any evidence for its case at trial.” ANALYSIS “It is well-settled that a party who challenges the ruling of a lower court must on appeal assign error to each articulated basis for that ruling.” Ferguson v. Stokes, 287 Va. 446 , 452 (2014) (quoting Manchester Oaks Homeowners Ass’n v

2016Layne v. Layne, 61 Va. App. 32, 37 , 733 S.E.2d 139, 141 (2012); Church, 24 Va. App. at 508 , 483 S.E.2d at 501 . -5- Father’s motion did not comply with the statutory scheme to terminate his parental rights and approve a goal of adoption.

2016Layne v. Layne, 61 Va. App. 32, 37 , 733 S.E.2d 139, 141 (2012); Church, 24 Va. App. at 508 , 483 S.E.2d at 501 . -5- Father’s motion did not comply with the statutory scheme to terminate his parental rights and approve a goal of adoption.

2011No supporting documentation exists in the record. -3- Father’s challenge to the circuit court’s ruling “presents [a] purely legal question[] of statutory construction [that] we review de novo.” Addison v. Jurgelsky, 281 Va. 205, 208 , 704 S.E.2d 402, 404 (2011).

2011No supporting documentation exists in the record. -3- Father’s challenge to the circuit court’s ruling “presents [a] purely legal question[] of statutory construction [that] we review de novo.” Addison v. Jurgelsky, 281 Va. 205, 208 , 704 S.E.2d 402, 404 (2011).

2009See Fadness v. Fadness, 52 Va. App. 833, 851 , 667 S.E.2d 857, 866 (2008) (“If the parties believed that the circuit court erred, it was their duty to present that error to us with legal authority to support their contention.”); Parks v. Parks, 52 Va. App. 663, 664 , 666 S.E.2d 547, 548 (2008).

2009See Fadness v. Fadness, 52 Va. App. 833, 851 , 667 S.E.2d 857, 866 (2008) (“If the parties believed that the circuit court erred, it was their duty to present that error to us with legal authority to support their contention.”); Parks v. Parks, 52 Va. App. 663, 664 , 666 S.E.2d 547, 548 (2008).

2009See Fadness v. Fadness, 52 Va. App. 833, 851 , 667 S.E.2d 857, 866 (2008) (“If the parties believed that the circuit court erred, it was their duty to present that error to us with legal authority to support their contention.”); Parks v. Parks, 52 Va. App. 663, 664 , 666 S.E.2d 547, 548 (2008).

2009See Fadness v. Fadness, 52 Va. App. 833, 851 , 667 S.E.2d 857, 866 (2008) (“If the parties believed that the circuit court erred, it was their duty to present that error to us with legal authority to support their contention.”); Parks v. Parks, 52 Va. App. 663, 664 , 666 S.E.2d 547, 548 (2008).

1997Issues 5 and 6 "In matters concerning custody and visitation, the welfare and best interests of the child are the 'primary, paramount, and controlling consideration[s].'" Kogon v. Ulerick, 12 Va. App. 595, 596 , 405 S.E.2d 441, 442 (1991) (citation omitted).

1997Issues 5 and 6 "In matters concerning custody and visitation, the welfare and best interests of the child are the 'primary, paramount, and controlling consideration[s].'" Kogon v. Ulerick, 12 Va. App. 595, 596 , 405 S.E.2d 441, 442 (1991) (citation omitted).