Craven v. Department of Social & Health Services

Linda Craven appeals from a disposition order in a dependency proceeding that placed her daughter, A.C., with A.C.’s father, Michael Riley. A commissioner referred the appeal to a panel of judges for accelerated review pursuant to RAP 18.12. Based on the recent decision in In re J.B.S., 123 Wn.2d 1, 863 P.2d 1344 (1993), we agree with Craven that the trial court erred in several respects, but we affirm the decision because any error was harmless.

The relevant facts are undisputed. Craven is the mother of A.C., born in August 1990. In December 1990, Craven was charged with two counts of second…