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HeadsUp for Washington State: Court Opinions From Monday, December 1, 2014

Monday, December 1, 2014 

To view the full text of these opinions, please visit: or Lexis subscribers may use the links below to access the cases on either or Lexis Advance. 

Division One of the Court of Appeals filed 2 new published opinion on Monday, December 1, 2014:

1. In re Dependency of G.G. / Dep't of Soc. & Health Servs. v. Salazar
No. 71241-1
(December 1, 2014)
2014 Wash. App. LEXIS 2806 (

2014 Wash. App. LEXIS 2806 (Lexis Advance)


Brief: The mother appealed from an order terminating her parental rights to her three children, contending that she was deprived of her right to counsel of choice when the trial court denied her motion for a continuance to hire private counsel. Because she had not selected substitute counsel and failed to show that she had the ability to obtain substitute counsel, the trial court did not violate her right to counsel of choice or abuse its discretion. Further, the record supported the court's finding of unfitness.

2. In re Marriage of Rostrom
No. 71860-6
(December 1, 2014)
2014 Wash. App. LEXIS 2807 (

2014 Wash. App. LEXIS 2807 (Lexis Advance)


Brief: The decision allowing the mother to move the parties' minor children to Australia was proper because the trial court considered the factors required by RCW 26.09.520, and substantial evidence supported the findings regarding the father's challenges with his daughter, his parenting skills, and his abuse of alcohol, which he minimized. Because the court's parenting plan did not include significant stipulations made by the parties about the trial court's continuing jurisdiction to modify and enforce its orders, the court remanded with directions to amend the parenting plan to incorporate those stipulations, to consider if it should require a bond to guarantee compliance with any parenting plan provisions, and to require the parties to register the amended parenting plan in the Australian Family Law Court.

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