the adequacy of such skills. W.Va.Code § 49-6~5(b). 32 . See Syl. pt. 2, Nancy Viola R. v. Randolph W., 177 W.Va. 710, 356 S.E.2d 464 (1987) ("A conviction of first degree murder of a child’s mother by his father and the father's prolonged incarceration in a penal institution for that conviction are significant factors to be considered in ascertaining the father’s fitness and in determining whether the father’s parental rights should be terminated.”). See also Syl. pt. 2, Kenneth B. v. Elmer Jimmy S., 184 W.Va. 49, 399 S.E.2d 192 (1990) (per curiam) (same). 33 . We note that this approach is consistent with the practice followed by a number of our sister jurisdictions. See, e.g., Ex parte D.O.G., 770 So.2d 597 (Ala.2000) (certiorari denied without opinion) (Hooper, C.J., dissenting) (<HOLDING>); In re Ronell A., 44 Cal.App.4th 1352, 52
holding that adult child who maintained his own residence separate from his fathers household but regularly vacationed and kept gear at his fathers vacation home was not a resident of his fathers household and therefore not an insured under his fathers insurance policy covering the vacation home holding that a parents responsibility to support his children is not suspended upon his incarceration and that imprisonment cannot be used as an excuse to escape parental obligations holding that fathers criminal activity resulting in incarceration did not constitute material change in circumstances justifying reduction in or termination of his child support obligations holding that a fathers failure to resolve his drug addiction as required by the permanency plan constituted grounds for termination of his parental rights recognizing that fathers parental rights were terminated based upon his incarceration and his behavior while in prison his history of substance abuse and the fact that his child support payments are in arrears