Toms v. Hanover Department of Social Services

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the decision to affirm the termination of parental rights mooted the parent’s challenge to the foster-care goal of adoption because affirmation of “the termination order necessarily subsumes this aspect of his appeal”
• distinguishing Code § 16.1-283(C)(2) as specifically requiring “a showing that DSS has provided ‘reasonable and appropriate’ services to a delinquent parent prior to terminating his rights”
• “[S]ubsection C termination decisions hinge not so much on the magnitude of the problem that created the original danger to the child, but on the demonstrated failure of the parent to make reasonable changes.”
• “Our decision to affirm the termination order necessarily subsumes this aspect of his appeal [a challenge to the foster care plan’s goal of adoption] because a preponderance-of-the-evidence standard governs judicial modifications of foster care plans.” (citations omitted)
• “Our decision to affirm the termination order necessarily subsumes this aspect of his appeal [a challenge to the foster care plan’s goal of adoption] because a preponderance-of-the-evidence standard governs judicial modifications of foster care plans.” (citations omitted)

Source: CourtListener parenthetical corpus (CC0).