J.B. v. Department of Social & Health Services

¶1 In 2013, the legislature amended the statute governing termination of parental rights. The legislature provided that “[i]f the parent is incarcerated, the court shall consider” a set of factors before determining that “continuation of the parent and child relationship clearly diminishes the child’s prospects for early integration into a stable and permanent home.” RCW 13.34.180(l)(f) (emphasis added). Petitioner J.B. argues that his parental rights cannot be terminated without express written findings of fact on these incarcerated parent factors. We hold that while explicit findings on the…