On March 12, 2026, the Supreme Court of Virginia issued its decision in Perkins v. Howington, addressing a question that may seem unusual at first: if a parent was under a court order not to contact a child, can that same court-ordered period of no contact later satisfy the no-contact requirement of a Virginia adoption statute that allows a case to proceed without that parent’s consent?
In Perkins v. Howington, the answer was …