## Facts

- Janet D., a 16-year-old with an intellectual disability and a tendency to run away, was adjudicated a deprived (dependent) child and placed in the custody of county Child Welfare Services (CWS).
- CWS placed Janet in an unsecured shelter (McIntyre Shelter), from which she ran away and was later recovered.
- The juvenile court ordered CWS to (1) find proper housing for Janet and (2) make arrangements to prevent her from running away.
- Thomas Carros, the CWS director, returned Janet to the same shelter and relayed generalized instructions to shelter staff to comply and communicate with Janet’s social worker.
- The shelter’s response consisted mainly of minimal measures (e.g., requiring pajamas/robe and suggesting Janet seek counseling), without affirmative supervision or coordinated planning.
- Janet’s attorney notified Carros in writing that CWS was not complying with the order; no effective changes followed.
- Over roughly six weeks, Janet ran away five times; she was violently attacked by other residents on one occasion (not reported to her social worker) and spent three days in the woods without food on another.
- Shelter staff testified they were untrained and unprepared to care for Janet and were not permitted to communicate with the social worker; supervisory testimony indicated the shelter could not meet Janet’s needs.
- The juvenile court found Carros in civil contempt for noncompliance and imposed a fine; Carros appealed.

## Issues

1. Whether the appeal should be dismissed as moot because Janet’s status had changed by the time of appellate review.
2. Whether the juvenile court’s order was sufficiently definite to support civil contempt where it required CWS to secure “proper housing” and “make arrangements” to prevent further runaways.
3. Whether the evidence supported a finding that the CWS director failed to take reasonable, good-faith steps to comply with the juvenile court’s mandate.

## Decision

- The Superior Court of Pennsylvania held the appeal was not moot because the issues were capable of repetition yet likely to evade appellate review in juvenile matters.
- The court affirmed the civil contempt adjudication and fine.
- The court concluded the placement order was sufficiently clear in its objectives and did not need to prescribe every implementation detail.
- The court held the record supported the finding that Carros failed to ensure meaningful compliance with the order.

## Legal Principles

- Civil contempt requires a court order that is clear, specific, and definite enough to inform the contemnor of required conduct; an order is not unenforceably vague merely because it leaves implementation to professional judgment.
- When a juvenile court directs a child welfare agency to provide appropriate placement and protective measures, responsible officials must take active, reasonable, good-faith steps to achieve the ordered objectives; nominal or passive measures may constitute noncompliance.
- An otherwise moot dispute may be reviewed when it is capable of repetition yet likely to evade review due to the short duration of juvenile placements and the time required for appellate proceedings.

## Conclusion

The court reviewed the contempt order despite changed circumstances and affirmed because the juvenile court’s directive required clear outcomes—appropriate placement and prevention planning—and the agency director’s minimal actions and lack of follow-through supported a finding of civil contempt.


Janet D. v. Carros, 240 Pa. Super. 291, 362 A.2d 1060 (Pa. Super. Ct. 1976)