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.