Gladin v. Department of Social & Health Services

¶1 This case requires us to clarify what the State must prove when seeking to terminate parental rights. The Court of Appeals has interpreted language from our decision in In re Dependency of J. C., 130 Wn.2d 418, 924 P.2d 21 (1996), to mean that when the State presents evidence sufficient to prove the element codified in RCW 13.34.180(l)(e), it has necessarily proved the element codified in RCW 13.34.180(l)(f). Consequently, the Court of Appeals affirmed the termination of the parental rights of *647K.D.S.’s father, Derek Gladin, because the State proved RCW 13.34.180(l)(e). We disagree with…