In re T.R.J.
661 A.2d 1086 (1995)
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Rule of Law:
When a court seeks to terminate the commitment of a neglected child between the ages of 18 and 21, it must explicitly find that such termination is no longer necessary to safeguard the child's welfare and is in the child's best interest, aligning with the statutory framework for neglect proceedings.
Facts:
- T.R.J. was 15 years old when his mother, who was mildly mentally retarded and dependent on her great aunt, was unable to provide proper care for him and his two siblings.
- T.R.J. often left his mother's care, resided with homeless people, wandered streets late at night, and was involved in an alleged breaking and entering incident.
- T.R.J. was diagnosed as an emotionally handicapped adolescent, and later, a psychological report indicated he suffered from pathological adolescent depression, strong suicidal tendencies, and required intensive psychotherapy.
- Throughout his commitment, T.R.J. struggled in various placements, including shelter care and group homes, often being truant from school, non-compliant with rules, or absconding.
- He was discharged from Children’s Square in Iowa for failing to comply with prescribed treatment after a serious altercation, despite previously showing progress by attempting to obtain his GED and working part-time.
- At the time of the proposed termination, T.R.J.'s mother indicated she wanted him to leave her home, claiming he was misbehaving and she had no money to provide him with food.
- T.R.J. directly told the trial court that he wanted a life, needed help, guidance, and discipline, and feared he could not make it alone, indicating his basic needs for food, shelter, education, and mental health care remained unmet.
Procedural Posture:
- A neglect petition was filed against T.R.J. and his two siblings, based on a stipulation signed by their mother.
- On January 21, 1988, the Family Division of the Superior Court adjudicated T.R.J. and his siblings as neglected children.
- On December 8, 1988, the trial court entered a dispositional order committing T.R.J. to the care and custody of the Department of Human Services (DHS) for two years.
- The trial court subsequently entered annual orders extending T.R.J.'s commitment, including one on December 20, 1991, which extended it through March 1, 1993.
- On March 12, 1992, prior to the expiration of the latest extension, the Corporation Counsel made an oral motion for termination of T.R.J.’s commitment.
- The trial court granted the motion over T.R.J.’s objection and later denied T.R.J.’s motion for reconsideration.
- T.R.J. appealed the trial court's order terminating his commitment to the District of Columbia Court of Appeals (the court whose decision is being briefed).
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Issue:
Does the 'best interest of the child' standard apply when the government seeks to terminate the commitment of a neglected child, aged 18 to 21, prior to their twenty-first birthday, even if the child is perceived as unable to benefit from or unwilling to cooperate with services?
Opinions:
Majority - Wagner, Chief Judge
Yes, the 'best interest of the child' standard applies when the Superior Court considers terminating the commitment of a neglected child prior to their twenty-first birthday. The court, acting as parens patriae, has a well-established role to protect the best interest of the child throughout neglect proceedings, from initial adjudication to dispositional orders, as reinforced by D.C.Code §§ 16-2323(d) and -2320(a). The trial court erred by focusing predominantly on T.R.J.'s perceived unwillingness or inability to benefit from services and the Department of Human Services' (DHS) resource limitations, rather than explicitly framing its termination finding in terms of T.R.J.'s best interest and whether continued commitment was no longer necessary to safeguard his welfare. While public interest may be a factor in delinquency cases, it does not supersede the child's welfare in neglect proceedings. The court's jurisdiction over neglected children extends until age 21, and parents' support obligations typically continue to that age, underscoring the ongoing responsibility to ensure the child's best interest is met.
Analysis:
This case clarifies the standard for terminating commitment in neglected child cases, particularly for older youth nearing the age of majority. It reinforces the court's parens patriae responsibility, ensuring that the government cannot cease services for neglected children aged 18-21 based solely on resource constraints or a child's perceived non-compliance without explicitly determining it to be in the child's best interest. The ruling demands a more rigorous evidentiary basis for termination decisions, potentially impacting how state agencies manage 'aging out' youth in foster care systems by requiring continued focus on welfare rather than simply administrative closure. This decision acts as a check on governmental discretion, upholding the protective purpose of neglect statutes even when faced with challenging cases.
