Fairfax County Department of Family Services v. D.N.

ANNUNZIATA, Judge.

In this appeal, the Fairfax County Department of Family Services (“appellant”) contends the circuit court erred by prohibiting it from introducing evidence of physical abuse at a trial de novo to determine whether A.N. was an “abused or neglected child” as defined by Code § 16.1-228(1). We agree and reverse.

The facts relevant to our review follow. On October 4,1996, Child Protective Services received a confidential referral indicating that A.N., a fifteen-year-old girl, received several bruises as a result of disciplining by her father, S.N. Later that day, Christy Rogers,…