PARENTAL RIGHTS TERMINATION – RELATIVES PLACEMENT ACTION — DEFINITION OF RELATIVE. It’s true that the Virginia statutes require that in termination cases once a child is adjudicated “dependent” the court must consider granting custody to the child’s relatives rather than foster care or adoption. However, the definition of “relative” for these purposes does not include the mother’s brother’s girl friend’s parents. And yes, §16.1-283(A) does require consideration of all “reasonable adoptions for placement with immediate relatives” as a requirement of termination, but remote connections are not relatives of the child “as a matter of law.” The statutes used words that have an established common law meaning, and a court can presume that the Legislature intended that established meaning unless the statute clearly suggests otherwise. Under common law a “relative” means somebody related by blood or marriage. It has not been expanded statutorily to add adoptive relationships, but what was proposed here was honoring an even more tenuous connection. Bagley v. City of Richmond DSS, ___ Va. App. ___, ___S.E.2d ___, 38 FLR 1178 (1/31/12).