Department of Social & Health Services v. Saint-Louis

¶1 In 2013, the legislature enacted amendments to the dependency statutes to expressly address “the rights of parents who are incarcerated.” Final B. Rep. on Substitute H.B. 1284, 63d Leg., Reg. Sess. (Wash. *1062013) (SHB 1284). One critical provision in those amendments requires the dependency court to consider several factors “[i]f the parent is incarcerated.” RCW 13.34.180(1)(f) (emphasis added). Those factors bar a court from assuming that incarceration will make it impossible to parent; they focus instead on the sufficiency of the Department of Social and Health Services’ (Department)…