Virginia's Court of Appeals overturned an adoption because the incarcerated father was not allowed transportation to the hearing on whether his consent was being withheld contrary to the best interests of the child, nor any other way to participate, in Alvis v. Thornton, 4/10/18. The trial court, denying his motion for transportation, had cited Social Services' report and his convictions for burglary, larceny, and entering a house to commit assault. Remanded for a new hearing.