In re T.B.

Summary

The Supreme Court of Appeals of West Virginia affirmed the termination of petitioner father S.B.'s parental rights to T.B. The court held that the record supported findings that there was no reasonable likelihood the conditions of neglect could be corrected and that termination was necessary for the child's welfare, making a less-restrictive disposition unnecessary.

Holdings

1. The circuit court did not clearly err in finding that termination of the father's parental rights was necessary for the child's welfare where the father had no bond with the child, failed to develop a relationship during the proceedings, failed to provide financial or emotional support or adequate housing, failed to attend hearings, and exercised only one visit.
2. A less-restrictive disposition, including a relative guardianship, was not required because the circuit court properly found that there was no reasonable likelihood that the conditions of abuse and neglect could be substantially corrected in the near future.

Questions Presented

1. Whether the circuit court erred by finding that termination of the father's parental rights was necessary for the child's welfare.
2. Whether the circuit court was required to impose a less-restrictive disposition, such as a relative guardianship, before terminating parental rights.

Disposition

affirmed