Haugen v. Shenandoah Valley Social Services

Holding

In this appeal of a judgment entered by the Court of Appeals, we consider whether a transcript or statement of facts was necessary for the court to determine: whether the circuit court erred by refusing to require an incarcerated parent’s presence during a hearing to terminate her parental rights; and whether as a matter of common law the circuit court abused its discretion by failing to grant a continuance to that parent, who participated by telephone, when federal prison officials directed her to terminate her participation.