## Facts

- Cynthia Nell Snyder, a 16-year-old high school student with above-average grades, experienced escalating conflict with her parents, described as a collapse of communication and severe emotional strain within the home.
- Cynthia’s parents imposed strict limitations on her activities, which contributed to worsening family conflict and Cynthia’s refusal to remain at home.
- Cynthia’s father brought her to the Youth Service Center, and she was placed in a receiving home.
- Cynthia first petitioned juvenile court to be declared a dependent child based on allegations attacking parental fitness; the court rejected those allegations and ordered her returned home.
- Cynthia later sought help from a youth service agency and again came to the Youth Service Center; a second petition was filed alleging she was an incorrigible child—beyond her parents’ control due to her own conduct or nature.
- After a temporary custody hearing, Cynthia was placed in a foster home pending fact-finding.
- At a contested hearing, Cynthia stated she understood the allegations and absolutely refused to return home; testimony was also received from her parents, sister, counselor, and a psychiatrist.
- A juvenile court commissioner found Cynthia incorrigible under the statute, ordered foster placement under court supervision, and required ongoing family counseling; a juvenile court judge affirmed.
- Cynthia’s parents sought review, challenging the sufficiency of evidence and the juvenile court’s authority to grant relief over their objection.

## Issues

1. Whether substantial evidence supported the finding that Cynthia was “incorrigible” (beyond parental control due to her conduct or nature) under RCW 13.04.010(7).
2. Whether a minor may independently invoke juvenile court jurisdiction for dependency/incorrigibility and obtain a dependency determination over the objections of the child’s natural parents.

## Decision

- The Washington Supreme Court affirmed the juvenile court’s finding that Cynthia was incorrigible and thus a dependent child.
- The court held that a minor may independently petition for a dependency determination under the Juvenile Court Law.
- The court held that, when statutory criteria are met, a dependency determination for a self-declared incorrigible child may prevail over parental objection.
- The court upheld the disposition placing Cynthia in foster care under juvenile court supervision with continuing family counseling.

## Legal Principles

- “Incorrigible” status under RCW 13.04.010(7) requires proof that the child is beyond the control and power of the parents by reason of the child’s conduct or nature.
- Appellate review of juvenile court fact-finding applies a substantial-evidence standard: evidence sufficient to persuade a fair-minded, rational person supports the finding.
- The Juvenile Court Law permits a minor to initiate dependency/incorrigibility proceedings; parental opposition does not bar the court from determining dependency based on statutory criteria.
- In dependency matters, the juvenile court may order placement outside the home and services such as counseling when authorized by statute and supported by the child’s circumstances.

## Conclusion

The court affirmed a finding that a teenager’s entrenched refusal to return home and the breakdown of the parent-child relationship constituted substantial evidence of statutory incorrigibility, and it confirmed that a minor may seek dependency relief that can be granted even over parental objection.


In re Welfare of Snyder, 85 Wn.2d 182, 532 P.2d 278 (Wash. 1975)