Department of Social & Health Services v. Saint-Louis

¶1 In 2013, the legislature amended the “Juvenile Court Act,” chapter 13.34 RCW, to ensure that the rights of incarcerated parents are protected throughout various stages of the dependency and termination process. One of these amendments is codified in RCW 13.34-.180(l)(f), the amended language of which states that “[i]f the parent is incarcerated,” the trial court must consider several factors before terminating the parent-child relationship. Here, the mother was not incarcerated at the time of the termination hearing but was incarcerated for numerous months during the dependency. She…