18 Va. App. The statutory amendments since the Sauer decision clarify the procedural schema for termination. Custody considerations now follow in a separate paragraph. The specific requirements for termination are defined in separate subsections that address each of the various factual situations that can arise. The need to consider granting custody to relatives is not an element of proof for any of those situations.
Logic suggests that the issues be separated and addressed in progressive sequence.
The fact that a relative might be a proper custodian cannot increase or decrease the probability that a parent is unfit. A court need only address placement with a relative if it must sever the parental relationship. The amendments since Sauer make clear that consideration of placement with a relative is part of the custody decision, not a prerequisite to the termination decision. Trivette's investigation of the Hawthorne family revealed the existence of other relatives in the Washington, D.C., area and in Radford, Virginia, but neither appellants, Lanina Jackson, B.H., nor Minnie Brown was able to provide names or addresses for these persons. Dr. Ramsden's testimony was accepted by the court in the form of a written letter, a summary of his testimony before the juvenile and domestic relations district court, and the notes taken by the guardian ad litem during the juvenile and domestic relations district court hearing.