In the case of MacLean v. Roanoke County Department of Social Services, the Virginia Court of Appeals, in an unpublished opinion, held that a mother's parental rights were properly terminated. The mother left her toddler at the entrance of her apartment complex under the auspices of going to the hospital, and later tested positive for substance abuse. She never received treatment for the substance abuse and failed to maintain conditions that would enable her to care for the child.