HS-88-038-AK
6-1800-1943-2
STATE OF MINNESOTA
OFFICE OF ADMINISTRATIVE HEARINGS
FOR THE MINNESOTA DEPARTMENT OF HUMAN SERVICES
In the Matter of the FINDINGS OF FACT,
Proposed Revocation CONCLUSIONS,
and Non-Renewal of the RECOMMENDATION,
Foster Care License AND MEMORANDUM
of Irene Koering
The above-entitled matter came on for hearing before Allan W. Klein,
Administrative Law Judge, on December 15, 1987, in Minneapolis. The record
closed at the end of the hearing on that date.
Appearing on behalf of Hennepin County was John St. Marie, Assistant
Hennepin County Attorney, A-2000 Government Center, Minneapolis, Minnesota
55487. Appearing on behalf of Irene Koering, the Licensee herein, was
Thomas Bennett Wilson III, Attorney at Law, 3940 West 49-1/2 Street, Edina,
Minnesota 55424.
Notice is hereby given that, pursuant to Minn. Stat. sec. 14.61 the final
decision of the Commissioner of Human Services shall not be made until this
Report has been made available to the parties to the proceeding for at least
ten days, and an opportunity has been afforded to each party adversely
affected to file exceptions and present argument to the Commissioner
Exceptions to this Report, if any, shall be filed with Commissioner Sandra S.
Gardebring, Second Floor Space Center Building, 444 Lafayette Road, St. Paul,
Minnesota 55101.
STATEMENT OF ISSUE
Should the family foster care license of Irene Koering be revoked or not
renewed because of an incident of alleged neglect which occurred in the course
of a medical emergency?
Based upon all of the proceedings herein, the Administrative Law Judge
makes the following:
FINDINGS OF FACT
1. Irene Koering (hereinafter "Koering" or Respondent") has been a
licensed foster parent since June of 1978, a period of roughly ten years. Her
home is located on Bloomington Avenue in Richfield.
2. During the ten years of licensure, she has cared for approximately
60 children and one adult. Twenty of these children were permanent placements
(relatively long term), while 40 were shelter placements (relatively short
term). She is currently licensed for five children, but had applied for
additional licensure for one specified adult (a 21-year-old woman who has been
living with her for some time).
3. Up to three years ago, all of Koering's permanent placements were
emotionally disturbed children. In the last few years, however, most of her
placements have been mentally retarded or mentally handicapped children.
4. On an average over the last three years, Respondent would have four
mentally handicapped children. These would include two ambulatory, and two
non-ambulatory.
5. Respondent has taken far more than the minimum required number of
training courses. She has spoken at informational meetings designed to
solicit new foster care parents, she has appeared in a video tape cassette on
teenage discipline, and she has taught classes for single foster parents.
6. At the present time, Respondent is caring for two children and one
adult. The adult is 21 years old, and Respondent made an application for a
license to allow this one adult to stay at her home pending the adult's
long-term placement in another facility where she is on a waiting list. This
adult has Down's Syndrome, and a full scale IQ of 56. She has resided with
Koering since July of 1985. Her social worker determined that continuing the
placement at the Koering foster home would be beneficial pending the outcome
of this appeal process and a final decision regarding the adult care license.
Ex. 7.
7. Stephanie W. is a two-year-old girl. She is multi-handicapped. She
has no ability to speak or otherwise communicate except on the most basic
level (smile and cry). She can receive stimulation only from her sense of
sound and sense of touch, as she is blind. She is also mentally retarded.
She is fed through a tube in her stomach, rather than eating through her mouth.
8. By June of 1987, Stephanie W.'s stomach tube was permanently inserted
into the side of her midsection, at approximately navel level, but off to one
side. It extended out from her body approximately ten inches. It was clamped
off. Stephanie could ingest only liquids through the tube. In June of 1987,
Stephanie weighed approximately 19 pounds.
9. On June 3, 1987, at approximately 11:15 a.m., Irene Koering received
a telephone call from Stephanie's day program, AccessAbility, Inc. This is
located in North Minneapolis. The telephone call was to inform Respondent
that the tube in Stephanie's stomach was half in and half out, and that
Stephanie needed immediate medical attention.
10. At the time of the telephone call, Ms. Koering had two children in
her care at home -- Randy W., a seven-month-old boy, and Rachel K., a six and
one-half year old girl.
11. Respondent's preferred medical provider for Stephanie's stomach tube
was Dr. David Rustad. After receiving the telephone call from Stephanie's day
program, Respondent called Dr. Rustad's office to see if he would be
available. She was told by a secretary there that he was not in the office,
but that he was at Children's Hospital (Minneapolis Children's Medical Center)
in South Minneapolis. The doctor's secretary informed Respondent that he
would be at the hospital until 12:40 p.m., and that if Respondent could get
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Stephanie to the hospital by that time, Dr. Rustad would see her in the
emergency room. The secretary indicated that she would call Dr. Rustad at the
hospital to alert him that Ms. Koering would be bringing Stephanie in.
12. Ms. Koering attempted to contact her back-up people to see if they
could watch Randy and Rachel while she took Stephanie to the emergency room.
She tried four people, none of whom could be reached. She determined to take
Randy and Rachel with her. She bundled them up, and set out to pick up
Stephanie.
13. When she arrived at the North Minneapolis day program, Respondent
discovered that Stephanie was screaming and exhibiting great pain. Stephanie
calmed down if she were laying flat, and so Respondent carried Stephanie in a
prone position, across her extended arms, out to the van. Respondent felt it
was necessary for Stephanie to be in a car seat during the ride to the
hospital, and so she placed her in one. Stephanie resumed her loud
screaming. Respondent had only seen Stephanie behave this way once before,
which was another incident where her tube had come out.
14. Respondent then drove to the Children's Medical Center. She had been
there several times before, both with her own biological children and with
foster children, but she had never before been to the emergency room there.
She located a parking space near an entrance, and parked the van. Despite the
screaming, Randy was asleep in his car seat. The radio had been playing
music. Respondent decided to allow Randy and Rachel to stay in the car while
she went to the emergency' room with Stephanie. She instructed Rachel to stay
in the van with Randy. She left the key in the ignition so the radio would
play. She left the doors unlocked. Rachel is not mentally handicapped, but
she is emotionally disturbed. She had been with Respondent for a little more
than two years. She was capable of appropriate behavior.
15. Randy, the seven-month-old, was born very prematurely. It is
believed that he is a likely candidate for apnea, but he has never actually
had any incidents of breathing cessation. Nonetheless, he has been connected
to an apnea monitor for at least as long as he has been at Respondent's home.
The monitor itself is a box, approximately eight inches by eight inches,
weighing around six pounds. It is usually powered by ordinary AC current, but
it contains a rechargeable battery which is supposedly good for 12 hours of
operation. Respondent, her two children, and her sister had all been trained
in the use of the apnea monitor and in CPR technique in case Randy should ever
need help.
16. The monitor indicates a problem in either breathing or heart rate by
emitting an audible beeping sound at a relatively high volume. Persons in the
Koering home have all been told that should the monitor ever begin beeping,
they are to locate Ms. Koering at once. One time the monitor did go off and
Rachel got Ms. Koering from a shower stall in the bathroom to alert her that
the alarm had gone off. The only times that the alarm has gone off have
always been a result of a malfunction of the unit.
17. Respondent arrived at the Children's Medical Center between 12:15 and
12:20. She entered the building, carrying Stephanie in her arms. She asked
where the emergency room was, and was told that it was at the other end of the
building. She had entered near the admissions area, not the emergency area.
She then proceeded down to the emergency room, where she announced herself and
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the purpose for her visit. She was informed that before anything could be
done for Stephanie, she would have to be admitted through the admissions
area. Respondent was frustrated and upset, because she believed that the time
was much closer to the 12:40 deadline than it actually was. She turned
around, and went back to the admissions area. There is at least half a
block's distance between the two areas. She carried Stephanie with her.
18. Respondent walked past the admissions desk and went outside to her
van. She looked in the back window of the van and observed that Randy was
awake and laughing, and that Rachel was playing with him. She did not tap on
the window or otherwise advise them that she was there.
19. Respondent went back into the Medical Center, and registered
Stephanie. Her registration was "clocked" as having occurred at 12:25 p.m.
Respondent then proceeded, still carrying Stephanie, back to the emergency
room. She then informed personnel on duty that she had two children waiting
in a car, that one of them was on a monitor, and that it was imperative that
she see Dr. Rustad promptly. She was informed that Dr. Rustad was not there,
and must be somewhere else in the hospital. Respondent waited while a nurse
went to look for the doctor. The nurse returned, indicating that she did not
find him. A few minutes later, Respondent again repeated her request, and the
nurse again went to look for the doctor, with the same results. Respondent
asked the nurse if there was parking closer to the emergency room, and the
nurse informed her that there was not. It was while they were discussing
parking that Respondent heard her name being called over the public address
system.
20. Approximately ten minutes after Respondent had registered, and after
she had left the admissions area to go back to the emergency room with
Stephanie, Rachel appeared in the admissions area asking for help with the
baby in the van because the apnea monitor had begun to beep. Medical
personnel were called to the van at 12:38 p.m., and attended to Randy. They
determined that the cause of the beeping was a battery problem with the
monitor, not a medical problem. Security personnel questioned Rachel about
who was in charge. Rachel indicated that she did not know where her foster
mother had gone, nor could she tell them her mother's complete name. A
security guard noticed a handicapped sticker with the name "Irene Koering" on
it, and had Koering paged over the hospitals public address system. At some
point during this process, the heart monitor began to beep again, and a life
support unit was called to the van. The life support unit and Respondent both
arrived at the van at approximately 1:02 p.m.
21. Respondent, upon hearing her name over the public address system,
went to the emergency room desk, where she was told to respond by telephone.
On the telephone, she was connected with the admissions area. She was
informed of the problem with the heart monitor. She she asked if somebody
could watch Stephanie while she dealt with this new problem. Both the
admissions area person and an individual in the emergency room agreed to watch
Stephanie. Stephanie was then left in their care while Respondent went out to
the van to see what was wrong with Randy.
22. The life support unit on Randy was checked, and it was determined
that he was fine (apart from being upset by all the activity) and that the
problem was with the monitor's battery pack.
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23. Upon determining that Randy was all right, the security guard
confronted Respondent about leaving the infant and a six-year-old unattended.
She replied that she had believed her visit to the emergency room was only
going to take a minute. The security guard later reported that her demeanor
was matter of fact, and that she did not seem upset or concerned.
24. Respondent got in the van, drove it around to the other end of the
hospital, located a parking space reasonably close to the emergency room, put
Randy in a stroller and, carrying the monitor, took Randy and Rachel inside to
the emergency room where they all waited for the doctor to appear. After some
additional wait, Stephanie was seen and treated by another doctor (not Dr.
Rustad). The procedure to reinsert the tube took only a couple of minutes,
and the group left the hospital at 1:30 p.m.
25. On that same day, a report of the incident was made to the Child
Protection Division. The division responded promptly, requesting a written
complaint and organizing an informational meeting for the next day, June 4.
Pursuant to routine procedures for these kinds of complaints, a variety of
personnel participated in the informational meeting -- licensing workers, case
management workers, child protection investigators and other county officials.
Those that could not attend were asked for input by telephone. one of the
placing social workers noted that one of his clients placed at the home had
graduated from high school on the afternoon of June 3, and that Ms. Koering
had arrived late for the graduation. She expressed frustration at being late
for the graduation, explaining that she had had to wait an hour to see a
doctor when taking another foster child to the emergency room. However, she
did not mention anything to him about the incident of the other foster
children having been left in the van. Following a thorough discussion of
facts and impressions about the foster home, the Child Protection Unit
determined to investigate the matter further because they feared that a child
(Randy) had been placed at risk of possible injury by Koering's conduct of
leaving him in the car unattended.
26. The Child Protection Unit conducted a thorough investigation of the
matter, speaking with numerous personnel at the hospital, the doctor's office,
and others. On July 10, a Child Protection worker made an unannounced visit
on Ms. Koering, accompanied by Koering's licensing worker, to interview her
about the incident. Ms. Koering was forthright, and gave the impression of
not being surprised to see an investigator involved in the matter. The only
substantial deviations between the events as described by Respondent to the
investigator and the events as the investigator pieced them together from
speaking with others were, (1) the time of arrival at the hospital (Respondent
thought it was much closer to the 12:40 deadline than the 12:15 to 12:20
actual arrival time, (2) whether or not Respondent had been there in the past
(Respondent claimed she had never been to the emergency room before, whereas a
nurse informed the investigator that Respondent had taken Stephanie there
twice before), and (3) whether or not Respondent's foster-daughter, Rachel,
had been instructed to "keep the whole thing a secret", which the investigator
determined was a possible cover-up. In light of the tremendous amount of
factual detail involved, these discrepancies are neither surprising nor
shocking. Each of them was discussed at length at the hearing. They are
resolved as follows:
a. Respondent must have arrived at the hospital between 12:15 and
12:20. The clock in her van is fast. That factor, plus the stress of
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having Stephanie screaming and trying to get from North Minneapolis to
South Minneapolis before the 12:40 deadline, account for Respondent's
belief that she arrived at the hospital much later than she actually did.
b. Respondent has not been to the emergency room at Children's
Medical Center in the past. She has picked up Stephanie at the Medical
Center, and visited her there while Stephanie was an in-patient, but she
has not been to the emergency room itself. Stephanie's prior visits to
the emergency room were with her biological mother, not Respondent.
C. Respondent did tell Rachel not to discuss the incident with
students or teachers at school. Rachel had a habit of discussing all
manner of family matters at school, a practice which disturbed
Respondent. Respondent attempted to tell Rachel that it was all right to
talk with her social worker and others, but Respondent doubts whether
Rachel understood the distinction. It is found that Respondent did not
attempt to have Rachel 'cover up" the incident from responsible
authorities.
27. On July 23, 1987, the Child Protection Unit completed an 11-page
report. The report acknowledged the extenuating circumstances of Respondent's
being concerned about the well-being of Stephanie, whom she believed to be in
great distress, but nevertheless concluded that leaving Randy and Rachel
unsupervised in an unlocked vehicle with the keys in the ignition constituted
substantiated neglect.
28. Shortly thereafter, on August 6, 1987, the licensing social worker
who handled the Koering home, and his supervisors, prepared a memo to the
Hennepin County foster care team. The gist of the memo was to set forth some
additional information which had been gathered since the June 23 report, and
to request that Koering be granted a waiver from a rule which would otherwise
prohibit the renewal of her license, or the issuance of the adult care license
which was then pending, because someone in the household had substantiated
evidence of child neglect.
29. Among the new evidence discovered between July 23 and August 6 was
that Respondent had been to the Medical Center before, but not to the
emergency room. Secondly, it was discovered that Respondent had looked into
the van between the time that she came from the emergency room to the
admissions area and her actually registering at the admissions area. Thirdly,
after returning to the emergency room, Respondent had twice told the nurse
that she had a baby on a monitor in the car, and needed to see the doctor
immediately. Finally, Respondent was confronted with the allegation that she
had attempted to have her daughter, Rachel, "cover-up" the incident.
Respondent satisfactorily explained that she had not done so, and further
explained that she knew very well that there would be an investigation as a
result of the incident. Each of these has been accepted by the Administrative
Law Judge.
30. Attached to the request for waiver was a proposed contract. The
contract would be between Koering and the licensing worker, and would place
limitations upon the number and types of children which Koering could have in
the home. Ex. 3. The request for waiver was submitted to the Department of
Human Services, which has not formally acted on it. However, the Department
orally directed the County to prepare a recommendation for revocation, thus
implicitly denying the requested waiver.
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31. On September 28, 1987, the State Department of Human Services issued
a Notice of and Order for Hearing, setting the hearing in the matter for
December 15. It was served upon Respondent and her attorney by mailing on
November 9, 1987.
32. Respondent's foster care license was scheduled to expire, routinely,
on May 1, 1987. For reasons having nothing to do with this incident, an
extension was granted to June 30, 1987 to complete the renewal process. The
renewal, and the granting of the adult license for one adult, are both "on
hold" pending the outcome of this proceeding.
33. Respondent has never had any serious allegations raised about the
conduct of her facility in the ten years that she has operated it. At one
point, there was a concern about sexual interaction between two young women at
the facility, but it was determined that there was no neglect on Respondent's
part. County personnel talked with her, and it was determined to change the
bedroom arrangements, separating the two. It was suggested at the hearing,
but not proven one way or the other, that in fact it was Respondent who
brought the matter to the attention of County authorities, seeking their
advice.
34. It continues to be the recommendation of both the licensing social
worker and his supervisor that probation is more appropriate than revocation.
They recommend that, for a limited period of time, the number of persons
allowed in the home be reduced, from five children to three children and one
adult. They continue to recommend that future placements include no more than
one non-ambulatory client at a time. They continue to recommend that there be
a qualified caretaker supervising the children at all times.
35. It is very difficult to find permanent placements for children such
as Stephanie W., Randy, Rachel, and many of the other children whom Respondent
has cared for. There is a serious shortage of placement alternatives for such
children. Respondent has learned how to care for such children, and has
developed the skills to do so. Her present licensing worker has complete
confidence in her abilities. Her prior licensing worker was shocked to hear
of the proposed revocation. Even after hearing the facts of the incident, she
would not have any hesitancy in having Respondent continue to be licensed
because "she's one of the best homes we have".
36. A licensed consulting psychologist who had a client placed in
Respondent's home testified that it takes a great deal of patience and
willingness to learn and understand new techniques needed to deal with
mentally retarded children. She would have no reservations about having any
of her clients continue to live there or go to live there. She was asked if
she felt that Respondent had neglected her client, and she responded: "To the
contrary, she is highly committed and has done an excellent job. She's more
than a good technician.' She went on to opine that it would be contrary to
the best interests of her client to have her removed from Respondent's care.
Her client has had several foster placements, and each has had problems
requiring a change. Her client has exhibited severe behavior problems every
time there has been a move. Her client has been with Respondent now for two
to three years and they are well adjusted to each other. It was the
psychologist's professional opinion that if the client were removed from
Respondent's care, it was likely that extreme behavior problems would again
occur, and the progress which has been made might be undone.
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37. A senior social worker who has a client at Respondent's facility
observed that Respondent has been very patient with her client's acting out
and that her client's behavior has very much improved since being at
Respondent's home. If Respondent continues to be licensed, the social worker
would have no concerns about her client remaining at Respondent's facility.
Her client had been in four foster homes, and that this is the longest
placement so far. She stated it's hard to find someone who would invest the
amount of time that Respondent has invested in her client.
38. A registered nurse from the Minneapolis Children's Medical Center
reported on the consistent concern which had been shown over Randy's potential
apnea. The nurse indicated that she had no reservations about the care that
Respondent has provided to Randy, characterizing Respondent as very capable
and loving.
39. A medical doctor from the Richfield Pediatric Clinic who also treated
Randy indicated that he was impressed by Respondent's dedication and concern
for Randy's well-being.
40. A senior social worker who has a client at Respondent's facility
indicated that he hoped his client could remain in the home during the appeal
process and during the time the final decision is made regarding the license.
He assessed his client's placement in the facility as "beneficial', stating
that Respondent had followed through fully on the social service plan and
cooperated with him in arranging various appointments for the client. His
client's behavior, physical appearance and independence have improved during
her stay with Respondent.
41. On September 23, 1987, the social worker for Rachel and her sister,
Angie, wrote a letter to Respondent, describing their current status. They
had left Respondent's care after the incident, but not as a result of the
incident. They had left because they were able to move home, which was part
of their case work plan. The social worker wrote Respondent:
. . . to let you know how much your work with Angie & Rachel is
appreciated. They gained a great sense of what expectations are
reasonable in a "normal family", both of discipline and
pleasures . . . . Your work laid the foundation in their minds
for a different view of family, and taught them how to function
in a more healthy setting. Give yourself a hug.
PERTINENT STATUTORY AND RULE EXCERPTS
Minn. Stat. sec. 626.556 (1986) defines "neglect" to mean:
Failure by a person responsible for a child's care to
supply a child with necessary food, clothing, shelter or
medical care when reasonably able to do so or failure to
protect a child from conditions or actions which imminently
and seriously endanger the child's physical or mental
health when reasonably able to do so.
Minn. Rule pt. 9545.0090 provides that a foster family home license:
shall not be issued or renewed where any person . . .
living in the household has any of the following
characteristics:
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(1) a conviction of, or admission of, or substantial
evidence of an act of assault, or child battering, or child
abuse, or child molesting, or child neglect;
Minn. Rule pt. 9545.0190, subp. 4, provides that, "Children in care shall
be adequately supervised at all times.'
Minn. Rule pt. 9545.0020, subp. 14, provides that failure to comply with
parts 9545.0010 to 9545.0260 shall be cause for denial, nonrenewal, or
revocation of a license.
Based on the foregoing Findings, the Administrative Law Judge makes the
following:
CONCLUSIONS
1. The Administrative Law Judge and the Commissioner of the Department
of Human Services have jurisdiction over this matter pursuant to Minn. Stat.
SS 245.781 to 245.812 (1986) and, to the extent necessary to vest continuing
jurisdiction, Minn. Stat. SS 245A.01 to 245A.16 (1987).
2. The appropriate statutory standard to use in evaluating the conduct
at issue here is the standard in effect at the time of the incident, namely,
Minn. Stat. SS 245.781 to 245.812 (1986). This was the statutory provision
cited in the Notice of and Order for Hearing, and it was the version in effect
at the time of the incident. Respondent's Motion to Dismiss this proceeding
because of an alleged failure to comply with certain provisions of Minn. Stat.
ch. 245A (1987), is DENIED.
3. The appropriate definition of "child neglect" to be used in this
proceeding is that contained in Minn. Stat. sec. 626.556, subd. 2(c) (1986).
This section was agreed to by all parties and the Administrative Law Judge at
the start of the hearing.
4. The actions of Irene Koering in leaving Rachel and Randy in the car
while she took Stephanie into the emergency room, under all of the facts and
circumstances which existed at the time of that incident, was not "neglect"
within the meaning of Minn. Stat. sec. 626.556 (1986). See, Memorandum.
5. Respondent did violate Minn. Rule pt. 9545.0190, subp. 4 by failing
to supervise the children "at all times". See, Memorandum.
6. The Commissioner has authority to make a license probationary. Minn.
Stat. sec. 245.801, subd. 3 and 4 (1986). Under the new statute, the
Commissioner may make a license probationary (section 245A.07, subd. 1 and
subd. 3) and, in addition, may impose "special conditions of licensure" within
the meaning of Minn. Stat. sec. 245A.04, subd. 7(6) (1987).
Based on the foregoing Conclusions, the Administrative Law Judge makes the
following:
RECOMMENDATION
That the proposed revocation and nonrenewal of the foster case license of
Irene Koering be DISMISSED, or,
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IN THE ALTERNATIVE, it is recommended that Respondent's license be made
probationary for a period of six months, during which time it is subject to
revocation if Respondent fails to properly supervise children.
Dated this 4th day of January, 1988.
ALLAN W. KLEIN
Administrative Law Judge
NOTICE
Pursuant to Minn. Stat. sec. 14.62, subd. 1, the agency is required to serve
its final decision upon each party and the Administrative Law Judge by first
class mail.
Reported: Tape Recorded - 3 Tapes
MEMORANDUM
Irene Koering was faced with a difficult situation. Not one of her four
back-up people could take care of the two children while she took Stephanie to
the emergency room. Therefore, she had to take the two children with her.
Upon arrival at the hospital, Respondent parked the van and took Stephanie
in. Respondent had hoped that she was at the emergency room door and that the
doctor would be waiting for her. She knew from past experience that the
reinsertion procedure was very fast. It was not physically possible for her
to carry Stephanie so as to minimize her pain and to also carry Randy along
with his monitor box. Based on these facts, she elected to leave Rachel and
Randy in the van while she took Stephanie inside the hospital.
In hindsight, there were better ways that this could have been handled.
Once Respondent realized that she was not at the emergency room, she could
have requested that someone watch Stephanie while she went out and got Randy
and Rachel and brought them in. Even when she got to the emergency room and
was told she had to go back and register, she could have asked someone there
to watch Stephanie while she went back, got the two children out of the van,
and then registered. In hindsight, she could have done a better job of
minimizing the time that the two children were exposed to the risk of being
unattended.
The statute, however, does not require perfection from foster parents.
Instead, it requires that they protect children from imminent and serious
danger "when reasonably able to do so". What Irene Koering did, under the
circumstances as she perceived them, was reasonable. It was not perfect, but
it was reasonable. Therefore, her actions did not constitute 'neglect".
The preferred disposition of this matter is total dismissal. However,
should the Commissioner desire to discipline Respondent (more than she has
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already been penalized) for her action, it would be appropriate to make her
license probationary for some limited period of time. The mental stress and
financial outlay which Respondent has already incurred as a result of this
incident has, in my opinion, already made an impression on Respondent, and it
is unlikely that she would make the same decisions again. Therefore, I
believe it is unnecessary to make the license probationary.
A.W.K.
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