Mahaney v. Mahaney
51 P. 3d 776, 146 Wash. 2d 878 (2002)

The trial court awarded custody of Natasha and Jesse Mahaney to their paternal grandparents. Experts diagnosed both children as having FAS. 51 P. 3d at 790.

In awarding custody to the grandparents, the trial court concluded that "[t]he mother is not presently able to address the children's special medical and psychological needs." 51 P. 3d at 785.