State of West Virginia, Petitioner Below, Appellant v. Michael M., Ii, and Angela H., Respondents Below, Appellees…

Summary

The court held that adoption is the preferred permanent out-of-home placement after parental rights have been terminated, and that permanent foster care may be used only if adoption would not serve the child’s best interests or no suitable adoptive home can be found. The court also held that post-termination visitation cannot be ordered without evidence and specific findings addressing detriment and the child’s best interests. It reversed the placement and visitation portions of the disposition orders and remanded for adoption proceedings and individualized visitation hearings.