Staff reviewed
NEW KENT COUNTY DEPARTMENT OF SOCIAL SERVICES V. AUTUMN SURRAN
— STAFF
Thus, because of the circuit court’s finding that the Department had not provided any services to father, we cannot say that the circuit court erred when it denied the Department’s petition to terminate father’s parental rights under Code § 16.1-283(C)(1) and (C)(2).
Va. Ct. App. · affirmed
Whether a parent's lack of contact during involuntary psychiatric hospitalization, with no agency services provided, warrants termination.