neglect hearing in District of Columbia

2009Cf. Williams v. United States, 859 A.2d 130, 136-37 (D.C.2004) (closed-circuit procedures warranted where child stopped re sponding to questioning, cried in witness room, and expressed fear of defendant); Ahmed, supra, 856 A.2d at 565 (child witness repeatedly expressed fear of testifying before father and ran away and slept outside for a night to avoid returning to court).

2009Cf. Williams v. United States, 859 A.2d 130, 136-37 (D.C.2004) (closed-circuit procedures warranted where child stopped responding *879 to questioning, cried in witness room, and expressed fear of defendant); Ahmed, supra, 856 A.2d at 565 (child witness repeatedly expressed fear of testifying before father and ran away and slept outside for a night to avoid returning to court).

2009Cf. Williams v. United States, 859 A.2d 130, 136-37 (D.C.2004) (closed-circuit procedures warranted where child stopped re sponding to questioning, cried in witness room, and expressed fear of defendant); Ahmed, supra, 856 A.2d at 565 (child witness repeatedly expressed fear of testifying before father and ran away and slept outside for a night to avoid returning to court).

2009Cf. Williams v. United States, 859 A.2d 130, 136-37 (D.C.2004) (closed-circuit procedures warranted where child stopped re sponding to questioning, cried in witness room, and expressed fear of defendant); Ahmed, supra, 856 A.2d at 565 (child witness repeatedly expressed fear of testifying before father and ran away and slept outside for a night to avoid returning to court).

2004Appellant has not raised any argument that the finding of neglect as to him was unnecessary given the neglect finding as to the children's mother. "[T]he statutory scheme ... is sufficiently durable to allow full resolution of all the neglect allegations even after the child has been found to be neglected based on only the allegations with respect to one parent." In re J.W., 837 A.2d 40, 44 (D.C.2003) (rejecting appellant father's argument that the trial court had no jurisdiction to adjudicate a neglect claim as to him where the mother had already stipulated to neglect because inter alia "indi

2004Appellant has not raised any argument that the finding of neglect as to him was unnecessary given the neglect finding as to the children’s mother. "[T]he statutory scheme... is sufficiently durable to allow full resolution of all the neglect allegations even after the child has been found to be neglected based on only the allegations with respect to one parent.” In re J.W., 837 A.2d 40, 44 (D.C.2003) (rejecting appellant father’s argument that the trial court had no jurisdiction to adjudicate a neglect claim as to him where the mother had already stipulated to neglect because inter alia "indiv

2003See, e.g., Thompson v. District of Columbia, 407 A.2d 678 , 679 n. 2 (D.C.1979) (declining review of Fifth Amendment due process claim for failure to raise the issue below) (citing Valentine v. United States, 394 A.2d 1374 (D.C.1978); Robinson v. United States, 322 A.2d 271 (D.C.1974); In re W.E.P., 318 A.2d 286 (D.C.1974); Foster v. United States, 290 A.2d 176 (D.C.1972); Williams v. United States, 237 A.2d 539 (D.C.1968)); see also District of Columbia v. Helen Dwight Reid Educ.

2003See, e.g., Thompson v. District of Columbia, 407 A.2d 678 , 679 n. 2 (D.C.1979) (declining review of Fifth Amendment due process claim for failure to raise the issue below) (citing Valentine v. United States, 394 A.2d 1374 (D.C.1978); Robinson v. United States, 322 A.2d 271 (D.C.1974); In re W.E.P., 318 A.2d 286 (D.C.1974); Foster v. United States, 290 A.2d 176 (D.C.1972); Williams v. United States, 237 A.2d 539 (D.C.1968)); see also District of Columbia v. Helen Dwight Reid Educ.

2003See, e.g., Thompson v. District of Columbia, 407 A.2d 678 , 679 n. 2 (D.C.1979) (declining review of Fifth Amendment due process claim for failure to raise the issue below) (citing Valentine v. United States, 394 A.2d 1374 (D.C.1978); Robinson v. United States, 322 A.2d 271 (D.C.1974); In re W.E.P., 318 A.2d 286 (D.C.1974); Foster v. United States, 290 A.2d 176 (D.C.1972); Williams v. United States, 237 A.2d 539 (D.C.1968)); see also District of Columbia v. Helen Dwight Reid Educ.

2003See, e.g., Thompson v. District of Columbia, 407 A.2d 678 , 679 n. 2 (D.C.1979) (declining review of Fifth Amendment due process claim for failure to raise the issue below) (citing Valentine v. United States, 394 A.2d 1374 (D.C.1978); Robinson v. United States, 322 A.2d 271 (D.C.1974); In re W.E.P., 318 A.2d 286 (D.C.1974); Foster v. United States, 290 A.2d 176 (D.C.1972); Williams v. United States, 237 A.2d 539 (D.C.1968)); see also District of Columbia v. Helen Dwight Reid Educ.

1984Appellee asks us to compare In re C.I.T., supra, 369 A.2d at 172 , with In re L.E.M., 164 A.2d 345, 349 (D.C.1960).

1984Appellee asks us to compare In re C.I.T., supra, 369 A.2d at 172 , with In re L.E.M., 164 A.2d 345, 349 (D.C.1960).

2012Moreover, it is our “general practice” 5 to accept a concession by the government that the trial court committed error, “especially where, as here, the government appears to have deliberately conceded [the] issue as a matter of appellate strategy, rather than merely failing to argue the point inadvertently.” Ellis v. United States, 941 A.2d 1042, 1048 (D.C.2008) (quoting Rose v. United States, 629 A.2d 526, 536 (D.C.1993)) (internal quotation marks omitted).

2012Moreover, it is our “general practice” 5 to accept a concession by the government that the trial court committed error, “especially where, as here, the government appears to have deliberately conceded [the] issue as a matter of appellate strategy, rather than merely failing to argue the point inadvertently.” Ellis v. United States, 941 A.2d 1042, 1048 (D.C.2008) (quoting Rose v. United States, 629 A.2d 526, 536 (D.C.1993)) (internal quotation marks omitted).

2003See, e.g., In re A.B.E., 564 A.2d 751, 755 (D.C.1989) (while the rights of a natural parent to raise a child are subject to due process protection, “these rights are not absolute, and must give way before the child’s best interests”); In re 485 A.2d 180 , 184 (D.C.1984) (parent “cannot insist that ... [she] has an interest which should prevail” over that of the child).

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings

1990S.2d 686, 687, 484 N.E.2d 1038, 1039 (1985); In re J.K., 49 Wash.App. 670 , 745 P.2d 1304, 1306 (1987); In re Colin R, 63 Md.App. 684, 693 , 493 A.2d 1083, 1089 (1985); In re O.E.P., 654 P.2d 312, 315-317 (Colo.1982) (en banc); In re K.B., T.B., and S.B., 302 N.W.2d 410, 411 (S.D.1981); Tucker v. Marion County Dept. of Public Welfare, 408 N.E.2d 814, 819-820 (Ind.1980). [4] See D.C.Code § 16-2322(a) (an order placing legal custody of a child in a department, agency, or institution must be reviewed after two years but may last a shorter period of time); §§ 16-2331 to -2335 (neglect proceedings