time of the termination hearing (Virginia) · Go Syfert
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time of the termination hearing in Virginia

15 Virginia opinions name it 1 courts 2003–2020 0 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Frye v. Spottegreen
vactapp · 1987 · cited in 3 Virginia opinions naming this issue, 2006–2012
2 sentences

2012Although at the time of the termination hearing Beard was married and testified Radosinovich was no longer in her life, she permitted Radosinovich to remain or to re-enter the lives of her children after a report of sexual abuse and, after she received sexual abuse counseling, she permitted him in the residence despite a court order barring him, and she permitted him to be alone with the children. “‘[P]ast actions and relationships over a meaningful period serve as good indicators of what the future may be expected to hold.’” Linkous v. Kingery, 10 Va. App. 45, 56 , 390 S.E.2d 188, 194 (1990)

2012Although at the time of the termination hearing Beard was married and testified Radosinovich was no longer in her life, she permitted Radosinovich to remain or to re-enter the lives of her children after a report of sexual abuse and, after she received sexual abuse counseling, she permitted him in the residence despite a court order barring him, and she permitted him to be alone with the children. “‘[P]ast actions and relationships over a meaningful period serve as good indicators of what the future may be expected to hold.’” Linkous v. Kingery, 10 Va. App. 45, 56 , 390 S.E.2d 188, 194 (1990)

33
Linkous v. Kingerygreen
vactapp · 1990 · cited in 3 Virginia opinions naming this issue, 2006–2012
2 sentences

2012Although at the time of the termination hearing Beard was married and testified Radosinovich was no longer in her life, she permitted Radosinovich to remain or to re-enter the lives of her children after a report of sexual abuse and, after she received sexual abuse counseling, she permitted him in the residence despite a court order barring him, and she permitted him to be alone with the children. “‘[P]ast actions and relationships over a meaningful period serve as good indicators of what the future may be expected to hold.’” Linkous v. Kingery, 10 Va. App. 45, 56 , 390 S.E.2d 188, 194 (1990)

2012Although at the time of the termination hearing Beard was married and testified Radosinovich was no longer in her life, she permitted Radosinovich to remain or to re-enter the lives of her children after a report of sexual abuse and, after she received sexual abuse counseling, she permitted him in the residence despite a court order barring him, and she permitted him to be alone with the children. “‘[P]ast actions and relationships over a meaningful period serve as good indicators of what the future may be expected to hold.’” Linkous v. Kingery, 10 Va. App. 45, 56 , 390 S.E.2d 188, 194 (1990)

33
Ferguson v. Stafford County Department of Social Servicesgreen
vactapp · 1992 · cited in 2 Virginia opinions naming this issue, 2005–2005
2 sentences

2005Servs., 14 Va. App. 333, 338 , 417 S.E.2d 1, 4 (1992), we have held that the trial judge “must determine what constitutes reasonable and appropriate efforts given the facts before the court.” Id. at 338-39 , 417 S.E.2d at 4 (citation omitted).

2005Servs., 14 Va. App. 333, 338 , 417 S.E.2d 1, 4 (1992), we have held that the trial judge “must determine what constitutes reasonable and appropriate efforts given the facts before the court.” Id. at 338-39 , 417 S.E.2d at 4 (citation omitted).

22
Akers v. Fauquier County Department of Social Servicesgreen
vactapp · 2004 · cited in 3 Virginia opinions naming this issue, 2007–2011
2 sentences

2011Servs., 44 Va. App. 247, 259 , 604 S.E.2d 737, 742 (2004) (“The best interests of the child are to be determined at the time of the termination hearing.”).

2011Servs., 44 Va. App. 247, 259 , 604 S.E.2d 737, 742 (2004) (“The best interests of the child are to be determined at the time of the termination hearing.”).

13
Logan v. Fairfax County Department of Human Developmentgreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008See Logan v. Fairfax County Dep’t of Human Dev., 13 Va. App. 123, 128 , 409 S.E.2d 460, 462 (1991). 2 So viewed, the evidence proved that at the time of the termination hearing in the trial court, T.G. was seven and one-half years old, T.M. was four and one-half years old, and L.M. was two and one-half years old. 3 In September 2005, at the time of L.M.’s birth, he and mother tested positive for cocaine and marijuana.

2008See Logan v. Fairfax County Dep’t of Human Dev., 13 Va. App. 123, 128 , 409 S.E.2d 460, 462 (1991). 2 So viewed, the evidence proved that at the time of the termination hearing in the trial court, T.G. was seven and one-half years old, T.M. was four and one-half years old, and L.M. was two and one-half years old. 3 In September 2005, at the time of L.M.’s birth, he and mother tested positive for cocaine and marijuana.

11
Helen & Robert W. v. Fairfax County Department of Human Developmentgreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 2007–2007
2 sentences

2007We recognize that “‘[t]he termination of [residual] parental rights is a grave, drastic and irreversible action.’” Helen W. v. Fairfax County Dep’t of Human Dev., 12 Va. App. 877, 883 , 407 S.E.2d 25, 28-29 (1991) (quoting Lowe v. Department of Public Welfare of the City of Richmond, 231 Va. 277, 280 , 343 S.E.2d 70, 72 (1986)).

2007We recognize that “‘[t]he termination of [residual] parental rights is a grave, drastic and irreversible action.’” Helen W. v. Fairfax County Dep’t of Human Dev., 12 Va. App. 877, 883 , 407 S.E.2d 25, 28-29 (1991) (quoting Lowe v. Department of Public Welfare of the City of Richmond, 231 Va. 277, 280 , 343 S.E.2d 70, 72 (1986)).

11
Lowe v. Richmond Dept. of Public Welfaregreen
va · 1986 · cited in 1 Virginia opinions naming this issue, 2007–2007
2 sentences

2007We recognize that “‘[t]he termination of [residual] parental rights is a grave, drastic and irreversible action.’” Helen W. v. Fairfax County Dep’t of Human Dev., 12 Va. App. 877, 883 , 407 S.E.2d 25, 28-29 (1991) (quoting Lowe v. Department of Public Welfare of the City of Richmond, 231 Va. 277, 280 , 343 S.E.2d 70, 72 (1986)).

2007We recognize that “‘[t]he termination of [residual] parental rights is a grave, drastic and irreversible action.’” Helen W. v. Fairfax County Dep’t of Human Dev., 12 Va. App. 877, 883 , 407 S.E.2d 25, 28-29 (1991) (quoting Lowe v. Department of Public Welfare of the City of Richmond, 231 Va. 277, 280 , 343 S.E.2d 70, 72 (1986)).

11
Lecky v. Reedgreen
vactapp · 1995 · cited in 1 Virginia opinions naming this issue, 2003–2003
2 sentences

2003"While age of the parent or parents is doubtless an appropriate consideration in assessing 'good cause' in the context of Code § 16.1-283(C), it is not a circumstance which prevails over the best interests of the child." Lecky v. Reed, 20 Va. App. 306, 312 , 456 S.E.2d 538, 541 (1995).

2003"While age of the parent or parents is doubtless an appropriate consideration in assessing 'good cause' in the context of Code § 16.1-283(C), it is not a circumstance which prevails over the best interests of the child." Lecky v. Reed, 20 Va. App. 306, 312 , 456 S.E.2d 538, 541 (1995).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Rochelle Lee Eaton v. Washington County Department of Social Services green
vactapp · 2016
1 sentence

2020Id. at 325-26 . -7- Here, the circuit court found that the evidence was sufficient to terminate mother’s parental rights under Code § 16.1-283(B), (C)(1), and (C)(2).

12020–2020
Dung Thi Thach and Carlos Mendoza v. Arlington County Department of Human Services green
vactapp · 2014
1 sentence

2017Id.

12017–2017
Toms v. Hanover Department of Social Services green
vactapp · 2005
2 sentences

2008By her own description, she was living in housing that was “technically shelter.” “Virginia law recognizes the ‘maxim that, sometimes, the most reliable way to gauge a person’s future actions is to examine those of his past.’” Toms, 46 Va. App. at 267-68 , 616 S.E.2d at 770 (quoting Petry v. Petry, 41 Va. App. 782, 793 , 489 S.E.2d 458, 463 (2003)).

2008By her own description, she was living in housing that was “technically shelter.” “Virginia law recognizes the ‘maxim that, sometimes, the most reliable way to gauge a person’s future actions is to examine those of his past.’” Toms, 46 Va. App. at 267-68 , 616 S.E.2d at 770 (quoting Petry v. Petry, 41 Va. App. 782, 793 , 489 S.E.2d 458, 463 (2003)).

12008–2008
Petry v. Petry green
vactapp · 2003
1 sentence

2008By her own description, she was living in housing that was “technically shelter.” “Virginia law recognizes the ‘maxim that, sometimes, the most reliable way to gauge a person’s future actions is to examine those of his past.’” Toms, 46 Va. App. at 267-68 , 616 S.E.2d at 770 (quoting Petry v. Petry, 41 Va. App. 782, 793 , 489 S.E.2d 458, 463 (2003)).

12008–2008
L.G. v. Amherst County Department of Social Services green
vactapp · 2003
2 sentences

2004In our subsequent decision in L.G., 41 Va.App. 51 , 581 S.E.2d 886 , we found that the trial court did not consider the mother’s efforts of rehabilitation after the twelve-month period had expired.

2004In our subsequent decision in L.G., 41 Va.App. 51 , 581 S.E.2d 886 , we found that the trial court did not consider the mother’s efforts of rehabilitation after the twelve-month period had expired.

12004–2004

Statutes the citing opinions construe

VA § Va. Code Ann. § 16.1-283 (15) VA § Va. Code Ann. § 17.1-413 (14)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IN 669 (1984–2023) IA 655 (1989–2026) NC 207 (1994–2026) MI 121 (1999–2026) PA 69 (2006–2026) OR 39 (1997–2026) GA 36 (1995–2018) CO 24 (1998–2026) NE 23 (2003–2026) AR 21 (2002–2025) TX 19 (1990–2022) AZ 19 (2009–2026) VA 15 (2003–2020) WA 12 (1987–2026) CA 10 (1991–2015) AL 9 (2003–2017) MO 9 (1985–2022) ME 8 (2010–2020) KS 8 (2008–2025) UT 7 (1998–2011) MN 7 (1980–1990) MT 6 (2006–2026) LA 4 (1999–2016) CT 4 (2016–2020) TN 3 (2003–2021) NM 3 (2002–2021) FL 3 (2004–2009) IL 2 (2020–2021) VT 2 (2011–2012) ID 2 (2021–2022) AK 2 (1988–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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