8 canonical passages across 4 cases, quoted by 45 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Sauer v. Franklin County Department of Social Services.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Sauer v. Franklin County Department of Social Services Anchor | green | “before termination of parental rights by the court, the agency seeking termination has an affirmative duty to investigate all reasonable options for placement with immediate relatives.” | 12 |
| 2 | Mary Anne Rowe v. Charles S. Rowe | green | “where experts offer conflicting testimony, it is within the discretion of the trial court to select either opinion.” | 10 |
| 3 | Hawthorne v. Smyth County Department of Social Services | green | “a vain and useless undertaking.” | 7 |
| 4 | Sauer v. Franklin County Department of Social Services | green | “in every case to investigate the home of every relative of the children, however remote, as a potential placement.” | 4 |
| 5 | Hawthorne v. Smyth County Department of Social Services | green | “dss had a duty to investigate placement of b.h. with relatives before the court could terminate appellants' parental rights.” | 3 |
| 6 | Hawthorne v. Smyth County Department of Social Services | green | “it is well established in virginia that a court will not compel 'a vain and useless undertaking.” | 3 |
| 7 | Lowe v. Richmond Dept. of Public Welfare | green | “other remedies should be sought when available.” | 3 |
| 8 | Sauer v. Franklin County Department of Social Services | green | “failed to exhaust its potential viable alternatives for placement.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.