Department of Social & Health Services v. Gabhart
Court of Appeals of Washington
1Opinion of the Court
¶1
Schindler, J.
Richard Smith and Heidi Gabhart are the parents of RH.V.S. Smith and Gabhart seek reversal of the order of dependency and the disposition order. The court found P.H.V.S. dependent because neither parent was capable of adequately caring for the child such that the circumstances constituted a substantial danger to the child’s psychological or physical development under RCW 13.34.030(6)(c). Smith contends the absence of his guardian ad litem (GAL) during a portion of the dependency fact-finding hearing violated the mandatory statutory and GALR requirements and his right to due…
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