Revised Code of Washington
Wash. Rev. Code § 13.34.132 (2026)
✓ current as of May 2026
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A court may order that a petition seeking termination of the parent and child relationship be filed if the following requirements are met:
(1) The court has removed the child from his or her home pursuant to RCW 13.34.130;
(2) Termination is recommended by the department;
(3) Termination is in the best interests of the child; and
(4) Because of the existence of aggravated circumstances, reasonable efforts to unify the family are not required. Notwithstanding the existence of aggravated circumstances, reasonable efforts may be required if the court or department determines it is in the best interests of the child. In determining whether aggravated circumstances exist by clear, cogent, and convincing evidence, the court shall consider one or more of the following:
(a) Conviction of the parent of rape of the child in the first, second, or third degree as defined in RCW 9A.44.073, 9A.44.076, and 9A.44.079;
(b) Conviction of the parent of criminal mistreatment of the child in the first or second degree as defined in RCW 9A.42.020 and 9A.42.030;
(c) Conviction of the parent of one of the following assault crimes, when the child is the victim: Assault in the first or second degree as defined in RCW 9A.36.011 and 9A.36.021 or assault of a child in the first or second degree as defined in RCW 9A.36.120 or 9A.36.130;
(d) Conviction of the parent of murder, manslaughter, or homicide by abuse of the child's other parent, sibling, or another child;
(e) Conviction of the parent of trafficking, or promoting commercial sexual abuse of a minor when the victim of the crime is the child, the child's other parent, a sibling of the child, or another child;
(f) Conviction of the parent of attempting, soliciting, or conspiring to commit a crime listed in (a), (b), (c), or (d) of this subsection;
(g) A finding by a court that a parent is a sexually violent predator as defined in RCW 71.09.020;
(h) Failure of the parent to complete available treatment ordered under this chapter or the equivalent laws of another state, where such failure has resulted in a prior termination of parental rights to another child and the parent has failed to effect significant change in the interim. In the case of a parent of an Indian child, as defined in RCW 13.38.040, the court shall also consider tribal efforts to assist the parent in completing treatment and make it possible for the child to return home;
(i) An infant under three years of age has been abandoned;
Notes:
Effective date—2013 c 302: See note following RCW 9.68A.090.
Notes of Decisions
Cited in 10
cases (2 in the last 5 years), 2001–2025 · leading case: Dep't of Soc. & Health Servs. v. Saint-Louis, 376 P.3d 1099 (Wash. 2016).
Dep't of Soc. & Health Servs. v. Saint-Louis, 376 P.3d 1099 (Wash. 2016). “§ 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
In Re Welfare of At, 34 P.3d 1246 (Wash. Ct. App. 2001). “[5] That language is now found in RCW 13.34.132(4)(a)-(i). [6] It is unknown from the record and from questioning at oral argument whether a child was even born of that offense.”
In re the Welfare of A.T., 109 Wash. App. 709 (Wash. Ct. App. 2001). “” RCW 13.34.132(4)6). Unfortunately, when the Legislature changed the statute, it created another problem.”
In Re Dependency of Dm, 149 P.3d 433 (Wash. Ct. App. 2006). “180(1)(e) and (f) are established beyond a reasonable doubt, the court shall consider whether one or more of the aggravated circumstances listed in RCW 13.34.132 exist; or (d) The allegation under RCW 13.”
In re Dependency of Baby Boy B., 554 P.3d 1196 (Wash. 2024). “Once a child is found dependent, the court will hold review hearings at least every 6 months to evaluate the parties’ progress and determine whether continued court supervision is necessary.”
In re Dependency of D.L.B. (Wash. 2016). “173, § 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
Janice M. v. Dep't of Soc. & Health Servs., 136 Wash. App. 387 (Wash. Ct. App. 2006). “180(l)(e) and (f) are established beyond a reasonable doubt, the court shall consider whether one or more of the aggravated circumstances listed in RCW 13.34.132 exist; or (d) The allegation under RCW 13.”
In re the Welfare of C.L., 131 Wash. App. 274 (Wash. Ct. App. 2006). ““[T]he child” in RCW 13.34.132 has indeed been held to refer to the child who is the subject of the dependency action.”
In Re The Dependency Of S.k-p., A Minor Child (Wash. Ct. App. 2017). “RCW 13.34.132. Assuming the termination goes to trial, the Department must prove the parent is unfit such that the legal right of 3 A “dependent” child is defined as any child who (a) has been abandoned; (b) is abused or neglected by a person legally responsible for the care of…”
Welfare of J.Y. & N.Y.; M.Y. v. DCYF (Wash. Ct. App. 2025). “RCW 13.34.132, .180. “A shelter care order is an extraordinary measure and is intended to be an interim solution in place for a short time.”
— Wash. Rev. Code § 13.34.132(4) — 2 cases
In re the Welfare of A.T., 109 Wash. App. 709 (Wash. Ct. App. 2001). “” RCW 13.34.132(4)6). Unfortunately, when the Legislature changed the statute, it created another problem.”
In re the Welfare of C.L., 131 Wash. App. 274 (Wash. Ct. App. 2006). ““[T]he child” in RCW 13.34.132 has indeed been held to refer to the child who is the subject of the dependency action.”
— Wash. Rev. Code § 13.34.132(4)(a) — 2 cases
In Re Welfare of At, 34 P.3d 1246 (Wash. Ct. App. 2001). “[5] That language is now found in RCW 13.34.132(4)(a)-(i). [6] It is unknown from the record and from questioning at oral argument whether a child was even born of that offense.”
In re the Welfare of A.T., 109 Wash. App. 709 (Wash. Ct. App. 2001). “” RCW 13.34.132(4)6). Unfortunately, when the Legislature changed the statute, it created another problem.”
— Wash. Rev. Code § 13.34.132(4)(g) — 2 cases
Dep't of Soc. & Health Servs. v. Saint-Louis, 376 P.3d 1099 (Wash. 2016). “§ 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
In re Dependency of D.L.B. (Wash. 2016). “173, § 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
— Wash. Rev. Code § 13.34.132(4)(h) — 2 cases
Dep't of Soc. & Health Servs. v. Saint-Louis, 376 P.3d 1099 (Wash. 2016). “§ 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
In re Dependency of D.L.B. (Wash. 2016). “173, § 3(4)(c); former RCW 13.34.132(4)(g) (2012) (currently codified as RCW 13.”
— Wash. Rev. Code § 13.34.132(4)(i) — 2 cases
In Re Welfare of At, 34 P.3d 1246 (Wash. Ct. App. 2001). “[5] That language is now found in RCW 13.34.132(4)(a)-(i). [6] It is unknown from the record and from questioning at oral argument whether a child was even born of that offense.”
In re the Welfare of A.T., 109 Wash. App. 709 (Wash. Ct. App. 2001). “” RCW 13.34.132(4)6). Unfortunately, when the Legislature changed the statute, it created another problem.”
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