Wash. Rev. Code » Title 13 · Chapter 13.34

Wash. Rev. Code § 13.34.180

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(1) A petition seeking termination of a parent and child relationship may be filed in juvenile court by any party to the dependency proceedings concerning that child. Such petition shall conform to the requirements of RCW 13.34.040, shall be served upon the parties as provided in RCW 13.34.070(8), and shall allege all of the following unless subsection (3) or (4) of this section applies:
(a) That the child has been found to be a dependent child;
(b) That the court has entered a dispositional order pursuant to RCW 13.34.130;
(c) That the child has been removed or will, at the time of the hearing, have been removed from the custody of the parent for a period of at least six months pursuant to a finding of dependency;
(d) That the services ordered under RCW 13.34.136 have been expressly and understandably offered or provided and all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future have been expressly and understandably offered or provided;
(e) That there is little likelihood that conditions will be remedied so that the child can be returned to the parent in the near future. A parent's failure to substantially improve parental deficiencies within 12 months following entry of the dispositional order shall give rise to a rebuttable presumption that there is little likelihood that conditions will be remedied so that the child can be returned to the parent in the near future. The presumption shall not arise unless the petitioner makes a showing that all necessary services reasonably capable of correcting the parental deficiencies within the foreseeable future have been clearly offered or provided. In determining whether the conditions will be remedied the court may consider, but is not limited to, the following factors:
(i) Use of intoxicating or controlled substances so as to render the parent incapable of providing proper care for the child for extended periods of time or for periods of time that present a risk of imminent harm to the child, and documented unwillingness of the parent to receive and complete treatment or documented multiple failed treatment attempts;
(ii) Psychological incapacity or mental deficiency of the parent that is so severe and chronic as to render the parent incapable of providing proper care for the child for extended periods of time or for periods of time that present a risk of imminent harm to the child, and documented unwillingness of the parent to receive and complete treatment or documentation that there is no treatment that can render the parent capable of providing proper care for the child in the near future; or
(iii) Failure of the parent to have contact with the child for an extended period of time after the filing of the dependency petition if the parent was provided an opportunity to have a relationship with the child by the department or the court and received documented notice of the potential consequences of this failure, except that the actual inability of a parent to have visitation with the child including, but not limited to, mitigating circumstances such as a parent's current or prior incarceration or service in the military does not in and of itself constitute failure to have contact with the child; and
(f) That continuation of the parent and child relationship clearly diminishes the child's prospects for early integration into a stable and permanent home. In making this determination, the court must consider the efforts taken by the department to support a guardianship and whether a guardianship is available as a permanent option for the child. If the parent is incarcerated, the court shall consider whether a parent maintains a meaningful role in his or her child's life based on factors identified in RCW 13.34.145(5)(b); whether the department made reasonable efforts as defined in this chapter; and whether particular barriers existed as described in RCW 13.34.145(5)(b) including, but not limited to, delays or barriers experienced in keeping the agency apprised of his or her location and in accessing visitation or other meaningful contact with the child.
(2) As evidence of rebuttal to any presumption established pursuant to subsection (1)(e) of this section, the court may consider the particular constraints of a parent's current or prior incarceration. Such evidence may include, but is not limited to, delays or barriers a parent may experience in keeping the agency apprised of his or her location and in accessing visitation or other meaningful contact with the child.
(3) In lieu of the allegations in subsection (1) of this section, the petition may allege that the child was found under such circumstances that the whereabouts of the child's parent are unknown and no person has acknowledged paternity or maternity and requested custody of the child within two months after the child was found.
(4) In lieu of the allegations in subsection (1)(b) through (f) of this section, the petition may allege that the parent has been convicted of:
(a) Murder in the first degree, murder in the second degree, or homicide by abuse as defined in chapter 9A.32 RCW against another child of the parent;
(b) Manslaughter in the first degree or manslaughter in the second degree, as defined in chapter 9A.32 RCW against another child of the parent;
(c) Attempting, conspiring, or soliciting another to commit one or more of the crimes listed in (a) or (b) of this subsection; or
(d) Assault in the first or second degree, as defined in chapter 9A.36 RCW, against the surviving child or another child of the parent.
(5) When a parent has been sentenced to a long-term incarceration and has maintained a meaningful role in the child's life considering the factors provided in RCW 13.34.145(5)(b), and it is in the best interest of the child, the department should consider a permanent placement that allows the parent to maintain a relationship with his or her child, such as, but not limited to, a guardianship pursuant to chapter 13.36 RCW.
(6) Notice of rights shall be served upon the parent, guardian, or legal custodian with the petition and shall be in substantially the following form:
"NOTICE
A petition for termination of parental rights has been filed against you. You have important legal rights and you must take steps to protect your interests. This petition could result in permanent loss of your parental rights.
1. You have the right to a fact-finding hearing before a judge.
2. You have the right to have a lawyer represent you at the hearing. A lawyer can look at the files in your case, talk to the department of children, youth, and families or other agencies, tell you about the law, help you understand your rights, and help you at hearings. If you cannot afford a lawyer, the court will appoint one to represent you. To get a court-appointed lawyer you must contact:    (explain local procedure)   .
3. At the hearing, you have the right to speak on your own behalf, to introduce evidence, to examine witnesses, and to receive a decision based solely on the evidence presented to the judge.
You should be present at this hearing.
You may call    (insert agency)    for more information about your child. The agency's name and telephone number are    (insert name and telephone number)   ."
[ 2022 c 127 s 2; 2018 c 284 s 20; (2018 c 284 s 19 expired July 1, 2018); 2017 3rd sp.s. c 6 s 308; 2013 c 173 s 4. Prior: 2009 c 520 s 34; 2009 c 477 s 5; 2001 c 332 s 4; 2000 c 122 s 25; 1998 c 314 s 4; 1997 c 280 s 2; prior: 1993 c 412 s 2; 1993 c 358 s 3; 1990 c 246 s 7; 1988 c 201 s 2; 1987 c 524 s 6; 1979 c 155 s 47; 1977 ex.s. c 291 s 46.]

Notes:

Effective date—2018 c 284 ss 3, 8, 13, 20, 33, 36, and 67: See note following RCW 13.34.030.
Expiration date—2018 c 284 ss 2, 7, 12, 19, 32, 35, and 66: See note following RCW 13.34.030.
Effective date—2017 3rd sp.s. c 6 ss 102, 104-115, 201-227, 301-337, 401-419, 501-513, 801-803, and 805-822: See note following RCW 43.216.025.
Conflict with federal requirements—2017 3rd sp.s. c 6: See RCW 43.216.908.
Findings—Intent—2009 c 477: See note following RCW 13.34.062.
Severability—1990 c 246: See note following RCW 13.34.060.
Effective date—Severability—1979 c 155: See notes following RCW 13.04.011.
Effective dates—Severability—1977 ex.s. c 291: See notes following RCW 13.04.005.
Notes of Decisions
Cited in 517 cases (90 in the last 5 years), 1979–2026 · leading case: In re the Parental Rights to K.M.M.
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In re the Parental Rights to K.M.M. (2016) wash · cites it 35× “A plain reading of RCW 13.34.180 and related statutes demonstrates that the unfitness inquiry goes beyond a parent’s deficiencies ¶52 There is no statutory definition of “unfitness,” but the statutory elements of RCW 13.”
Gladin v. Department of Social & Health Services (2013) wash · cites it 59× “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
In Re Welfare of AB (2010) wash · cites it 26× “" [17] We further held that "after reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190," [18] the trial judge had made the required findings, albeit implicitly.”
Salas v. Department of Social & Health Services (2010) wash · cites it 25× “” 17 We further held that “[a]fter reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190,” 18 the trial judge had made the required findings, albeit implicitly.”
J.B. v. Department of Social & Health Services (2017) wash · cites it 26× ““Consider” Requires Weighing on the Record ¶23 Next we must consider what action, exactly, RCW 13.34.180 mandates. Title 13 RCW requires, but does not define, that courts “consider” the incarceration factors.”
In re the Welfare of T.B. (2009) washctapp · cites it 22× “ANALYSIS f 15 The statutory framework for terminations imposes on the State the burden to prove all of the six elements of RCW 13.34.180. If the State satisfies this burden, it must then establish that the termination is in the children’s best interests.”
Department of Social & Health Services v. H.O. (2016) wash · cites it 16× “RCW 13.34.180(1). The only statutory prerequisite at issue in this appeal is (d): the provision of all necessary and reasonably available services capable of correcting parental deficiencies.”
Department of Social & Health Services v. Saint-Louis (2016) wash · cites it 16× “The other provision requires the court to “consider” three things “[i]f the parent is incarcerated” before determining whether “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home” (the…”
Franks v. State (In re M.-A.F.-S.) (2018) washctapp · cites it 25× “Franks contends the termination statutes, RCW 13.34.180 and .190, are unconstitutional both facially and as applied.”
Mares v. Department of Social & Health Services (2014) washctapp · cites it 16× “[W]hen an appellate court is faced with a record that omits an explicit finding of current parental unfitness, the appellate court can imply or infer the omitted finding if — but only if — all the facts and circumstances in the record (including but not limited to any…”
In Re Dependency of KNJ (2011) wash · cites it 13× “But we also noted that because the facts and circumstances of parental rights cases vary so widely, "the appellate court can imply or infer the omitted finding if—but only if—all the facts and circumstances in the record (including but not limited to any boiler plate findings…”
In re the Welfare of M.R.H. (2008) washctapp · cites it 12× “Based on the evidence presented at trial, the court did not err in finding termination was in the best interests of the children.”
Show all 517 citing cases →
— Wash. Rev. Code § 13.34.180(1) — 354 cases
In Re Welfare of AB (2010) wash “" [17] We further held that "after reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190," [18] the trial judge had made the required findings, albeit implicitly.”
Salas v. Department of Social & Health Services (2010) wash “” 17 We further held that “[a]fter reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190,” 18 the trial judge had made the required findings, albeit implicitly.”
In re the Parental Rights to K.M.M. (2016) wash “A plain reading of RCW 13.34.180 and related statutes demonstrates that the unfitness inquiry goes beyond a parent’s deficiencies ¶52 There is no statutory definition of “unfitness,” but the statutory elements of RCW 13.”
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
Jenkins v. Department of Social & Health Services (2011) wash
— Wash. Rev. Code § 13.34.180(1)(1) — 3 cases
In re the Termination of: J.E.L.D. (2016) washctapp
In re Dependency of D.L.B. (2016) wash
In re the Termination of: M.J. & M.J. (2015) washctapp
— Wash. Rev. Code § 13.34.180(1)(2)(5) — 1 case
Gausvik v. Perez (2002) waed
— Wash. Rev. Code § 13.34.180(1)(3) — 1 case
Dep Of Ab., Marvin Jordan, App v. Dshs State Of Washington (2019) washctapp
— Wash. Rev. Code § 13.34.180(1)(a) — 68 cases
In Re Dependency of KNJ (2011) wash “But we also noted that because the facts and circumstances of parental rights cases vary so widely, "the appellate court can imply or infer the omitted finding if—but only if—all the facts and circumstances in the record (including but not limited to any boiler plate findings…”
In re the Welfare of L.N.B.-L. (2010) washctapp
Department of Social & Health Services v. H.O. (2016) wash “RCW 13.34.180(1). The only statutory prerequisite at issue in this appeal is (d): the provision of all necessary and reasonably available services capable of correcting parental deficiencies.”
Department of Social & Health Services v. Saint-Louis (2016) wash “The other provision requires the court to “consider” three things “[i]f the parent is incarcerated” before determining whether “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home” (the…”
In Re Dependency of IJS (2005) washctapp
— Wash. Rev. Code § 13.34.180(1)(b) — 1 case
In Re The Dependency Of R.e. L-g (2023) washctapp
— Wash. Rev. Code § 13.34.180(1)(c) — 3 cases
In Re Dependency of Dm (2006) washctapp
Dep Of Ab., Mattie Macarthur v. Dshs State Of Washington (2017) washctapp
Dep Of Sls, Calvin Turner v. Dshs (2020) washctapp
— Wash. Rev. Code § 13.34.180(1)(d) — 185 cases
In re the Parental Rights to K.M.M. (2016) wash “A plain reading of RCW 13.34.180 and related statutes demonstrates that the unfitness inquiry goes beyond a parent’s deficiencies ¶52 There is no statutory definition of “unfitness,” but the statutory elements of RCW 13.”
Department of Social & Health Services v. H.O. (2016) wash “RCW 13.34.180(1). The only statutory prerequisite at issue in this appeal is (d): the provision of all necessary and reasonably available services capable of correcting parental deficiencies.”
In Re Welfare of Cs (2010) wash
In re the Welfare of C.S. (2010) wash
Mares v. Department of Social & Health Services (2014) washctapp “[W]hen an appellate court is faced with a record that omits an explicit finding of current parental unfitness, the appellate court can imply or infer the omitted finding if — but only if — all the facts and circumstances in the record (including but not limited to any…”
— Wash. Rev. Code § 13.34.180(1)(d)(e)(f) — 1 case
In Re Welfare of MRH (2008) washctapp
— Wash. Rev. Code § 13.34.180(1)(e) — 116 cases
In re the Parental Rights to K.M.M. (2016) wash “A plain reading of RCW 13.34.180 and related statutes demonstrates that the unfitness inquiry goes beyond a parent’s deficiencies ¶52 There is no statutory definition of “unfitness,” but the statutory elements of RCW 13.”
In Re Welfare of AB (2010) wash “" [17] We further held that "after reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190," [18] the trial judge had made the required findings, albeit implicitly.”
Department of Social & Health Services v. Saint-Louis (2016) wash “The other provision requires the court to “consider” three things “[i]f the parent is incarcerated” before determining whether “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home” (the…”
In Re Welfare of CB (2006) washctapp
Salas v. Department of Social & Health Services (2010) wash “” 17 We further held that “[a]fter reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190,” 18 the trial judge had made the required findings, albeit implicitly.”
— Wash. Rev. Code § 13.34.180(1)(e)(i) — 5 cases
In re Welfare of M.B. (2020) wash
In the Matter of the Dependency of: F.M. (2020) washctapp
In The Matter Of The Parental Rights To K.g.o. (2024) washctapp
In The Matter Of The Parental Rights To L.c.c-h. (2025) washctapp
In re: H. T. (2015) washctapp
— Wash. Rev. Code § 13.34.180(1)(e)(ii) — 2 cases
Dependency Of K.o. (2018) washctapp
In Re: A.B. (2014) washctapp
— Wash. Rev. Code § 13.34.180(1)(e)(iii) — 2 cases
Department of Social & Health Services v. Saint-Louis (2016) wash “The other provision requires the court to “consider” three things “[i]f the parent is incarcerated” before determining whether “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home” (the…”
In Re The Dep Of A.j.c. & L.c. (2022) washctapp
— Wash. Rev. Code § 13.34.180(1)(f) — 115 cases
Mares v. Department of Social & Health Services (2014) washctapp “[W]hen an appellate court is faced with a record that omits an explicit finding of current parental unfitness, the appellate court can imply or infer the omitted finding if — but only if — all the facts and circumstances in the record (including but not limited to any…”
Department of Social & Health Services v. Saint-Louis (2016) wash “The other provision requires the court to “consider” three things “[i]f the parent is incarcerated” before determining whether “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home” (the…”
Franks v. State (In re M.-A.F.-S.) (2018) washctapp “Franks contends the termination statutes, RCW 13.34.180 and .190, are unconstitutional both facially and as applied.”
J.B. v. Department of Social & Health Services (2017) wash ““Consider” Requires Weighing on the Record ¶23 Next we must consider what action, exactly, RCW 13.34.180 mandates. Title 13 RCW requires, but does not define, that courts “consider” the incarceration factors.”
In re the Parental Rights to K.M.M. (2016) wash “A plain reading of RCW 13.34.180 and related statutes demonstrates that the unfitness inquiry goes beyond a parent’s deficiencies ¶52 There is no statutory definition of “unfitness,” but the statutory elements of RCW 13.”
— Wash. Rev. Code § 13.34.180(1)(t) — 4 cases
In re the Termination of: M.J. & M.J. (2015) washctapp
In re Parental Rights to K.M.M. (2016) wash
In re the Termination Of: A.D.R. (2014) washctapp
In re the Termination of: K.J.B. (2015) washctapp
— Wash. Rev. Code § 13.34.180(2) — 7 cases
Department of Social & Health Services v. Saint-Louis (2015) washctapp
Department of Social & Health Services v. Chubb (1989) wash
Ferguson v. Department of Social & Health Services (1985) washctapp
In Re Dependency of Dm (2006) washctapp
Janice M. v. Department of Social & Health Services (2006) washctapp
— Wash. Rev. Code § 13.34.180(3) — 11 cases
Department of Social & Health Services v. Ferguson (1982) washctapp
Daniel B. v. Department of Social & Health Services (1995) washctapp
In Re the Welfare of Henderson (1981) washctapp
Ferguson v. Department of Social & Health Services (1985) washctapp
In Re the Welfare of Dodge (1981) washctapp
— Wash. Rev. Code § 13.34.180(4) — 39 cases
Department of Social & Health Services v. Ferguson (1982) washctapp
In Re the Welfare of Hall (1983) wash
New Hope of Washington v. Ramquist (1988) washctapp
B.S. v. Department of Social & Health Services (1999) washctapp
Robinson v. Department of Social & Health Services (1995) washctapp
— Wash. Rev. Code § 13.34.180(5) — 40 cases
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
K.C. v. Department of Social & Health Services (1996) wash
Department of Social & Health Services v. Jones (1995) wash
Krause v. Catholic Community Services (1987) washctapp
B.S. v. Department of Social & Health Services (1999) washctapp
— Wash. Rev. Code § 13.34.180(5)(a) — 3 cases
K.C. v. Department of Social & Health Services (1996) wash
In Re Dependency of JC (1996) wash
Kathy C. v. Department of Social & Health Services (1995) washctapp
— Wash. Rev. Code § 13.34.180(5)(b) — 2 cases
B.S. v. Department of Social & Health Services (1999) washctapp
In Re HS (1999) washctapp
— Wash. Rev. Code § 13.34.180(6) — 24 cases
In Re Dependency of KSC (1999) wash
Burrell v. Department of Social & Health Services (1999) wash
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
New Hope of Washington v. Ramquist (1988) washctapp
B.S. v. Department of Social & Health Services (1999) washctapp
— Wash. Rev. Code § 13.34.180(7) — 5 cases
Department of Social & Health Services v. Ferguson (1982) washctapp
State v. Grey (1998) washctapp
In Re Dependency of AG (1999) washctapp
In Re the Infant Child Skinner (1999) washctapp
In Re the Welfare of Dodge (1981) washctapp
— Wash. Rev. Code § 13.34.180(a) — 7 cases
In Re Dependency of AC (2004) washctapp
In Re Dependency of Knj (2009) washctapp
In Re The Welfare Of C.h-k., A Minor Child (2016) washctapp
In Re The Welfare Of: L.d. Ashley Dukellis v. Dshs (2016) washctapp
Dep Of Ab., Mattie Macarthur v. Dshs State Of Washington (2017) washctapp
— Wash. Rev. Code § 13.34.180(b) — 1 case
In Re Dependency of Knj (2009) washctapp
— Wash. Rev. Code § 13.34.180(d) — 13 cases
Applebee v. Department of Social & Health Services (2001) washctapp
In Re Dependency of AM (2001) washctapp
Dep Of M.n., Rachel Niehaus v. Dshs State Of Washington (2014) washctapp
In Re The Welfare Of C.h-k., A Minor Child (2016) washctapp
In Re The Dep Of D.w.n., Michell Nations v. Dshs (2017) washctapp
— Wash. Rev. Code § 13.34.180(d)(1) — 1 case
In Re The Dependency Of J.o., 10/17/13, Sonia Orozco-salgado v. Dshs (2017) washctapp
— Wash. Rev. Code § 13.34.180(e) — 15 cases
In Re Dependency of AC (2004) washctapp
In Re Dependency of IJS (2005) washctapp
In Re Dependency of DA (2004) washctapp
Dependency Of K.s.t. (2023) washctapp
In Re Welfare of Ag (2011) washctapp
— Wash. Rev. Code § 13.34.180(e)(ii) — 1 case
Dep Of T.m.s., Rebekka Mccray, App v. Dshs, State Of Washington (2013) washctapp
— Wash. Rev. Code § 13.34.180(f) — 18 cases
In Re Dependency of AC (2004) washctapp
Dependency Of K.s.t. (2023) washctapp
In Re The Dependency Of: E.a.e. Jerry Jasso-rodriguez, App. v. State Of Wa., Dshs, Res. (2017) washctapp
In The Matter Of The Dep. Of: A.a., Dob: 2/4/15, Andre Ash v. Dshs (2017) washctapp
Dependency Of: D.j.p., C.j.p., J.j.p., A.j.p., N.v.p., T.j.c.p. (2023) washctapp
— Wash. Rev. Code § 13.34.180(f)(1) — 1 case
In Re The Dependency Of L.a.h., Kautia Hopkins, App. V. Dcyf (2021) washctapp
— Wash. Rev. Code § 13.34.180(i)(a) — 2 cases
Dep Of Sls, Calvin Turner v. Dshs (2020) washctapp
In Re Dep Of M.c.d.p, Dob: 07/10/03 Heather Phillips, App. v. Dshs, Resp. (2013) washctapp
— Wash. Rev. Code § 13.34.180(l) — 11 cases
In re the Welfare of T.B. (2009) washctapp “ANALYSIS f 15 The statutory framework for terminations imposes on the State the burden to prove all of the six elements of RCW 13.34.180. If the State satisfies this burden, it must then establish that the termination is in the children’s best interests.”
In Re the Welfare of S.V.B. (1994) washctapp
In Re Dependency of JW (1998) washctapp
State v. Grey (1998) washctapp
Ferguson v. Department of Social & Health Services (1985) washctapp
— Wash. Rev. Code § 13.34.180(l)(a) — 17 cases
Jenkins v. Department of Social & Health Services (2011) wash
Department of Social & Health Services v. L.H. (2016) washctapp
Department of Social & Health Services v. Hackney-Farias (2007) washctapp
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
In re the Parental Rights to K.M.M. (2015) washctapp
— Wash. Rev. Code § 13.34.180(l)(b) — 3 cases
In re the Parental Rights to M.J. (2015) washctapp
In re the Dependency of K.N.J. (2009) washctapp
In re the Termination of: M.J. & M.J. (2015) washctapp
— Wash. Rev. Code § 13.34.180(l)(c) — 1 case
Janice M. v. Department of Social & Health Services (2006) washctapp
— Wash. Rev. Code § 13.34.180(l)(d) — 39 cases
In re the Termination of: IM.- M. & Z.M. - M. (2016) washctapp
Department of Social & Health Services v. Hackney-Farias (2007) washctapp
In re the Parental Rights to K.M.M. (2015) washctapp
In re the Welfare of T.B. (2009) washctapp “ANALYSIS f 15 The statutory framework for terminations imposes on the State the burden to prove all of the six elements of RCW 13.34.180. If the State satisfies this burden, it must then establish that the termination is in the children’s best interests.”
In re the Welfare of M.R.H. (2008) washctapp “Based on the evidence presented at trial, the court did not err in finding termination was in the best interests of the children.”
— Wash. Rev. Code § 13.34.180(l)(e) — 33 cases
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
In re the Welfare of T.B. (2009) washctapp “ANALYSIS f 15 The statutory framework for terminations imposes on the State the burden to prove all of the six elements of RCW 13.34.180. If the State satisfies this burden, it must then establish that the termination is in the children’s best interests.”
Department of Social & Health Services v. L.H. (2016) washctapp
In re the Welfare of C.B. (2006) washctapp
Salas v. Department of Social & Health Services (2010) wash “” 17 We further held that “[a]fter reviewing the entire record and examining the requirements of RCW 13.34.180 and 13.34.190,” 18 the trial judge had made the required findings, albeit implicitly.”
— Wash. Rev. Code § 13.34.180(l)(e)(ii) — 4 cases
Department of Social & Health Services v. E.I. (2014) washctapp
Department of Social & Health Services v. Luak (2012) wash
In re the Parental Rights to K.M.M. (2015) washctapp
In re the Parental Rights to B.P. (2015) washctapp
— Wash. Rev. Code § 13.34.180(l)(e)(iii) — 1 case
Department of Social & Health Services v. Saint-Louis (2015) washctapp
— Wash. Rev. Code § 13.34.180(l)(f) — 30 cases
Gladin v. Department of Social & Health Services (2013) wash “Gladin sought, and we granted, discretionary review to decide whether the Court of Appeals has properly construed RCW 13.34.180(1) and whether the State had sufficiently proved all the elements codified therein.”
J.B. v. Department of Social & Health Services (2017) wash ““Consider” Requires Weighing on the Record ¶23 Next we must consider what action, exactly, RCW 13.34.180 mandates. Title 13 RCW requires, but does not define, that courts “consider” the incarceration factors.”
In re the Welfare of R.H. (2013) washctapp
Department of Social & Health Services v. L.H. (2016) washctapp
Department of Social & Health Services v. Saint-Louis (2015) washctapp
— Wash. Rev. Code § 13.34.180(l)(t) — 4 cases
In re the Termination of: S. R. W. C. B-J. (2016) washctapp
In re Dependency of D.L.B. (2016) wash
In re the Termination of: M.J. & M.J. (2015) washctapp
In re the Welfare of: R.L. (2015) washctapp
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