Adoption of A.Z.F., Appeal of R.O.F.-F., father, Adoption of A.Z.F., Appeal of R.O.F.-F., father No. 67 WDA 2017

Child born January 2014 and adjudicated dependent September 2014 after a domestic-violence incident in which Father held Mother down, poured bleach on her, and held a gun to her head while Child was present; Father was criminally charged.
Father stipulated to facts at adjudication and had prior OCY involvement concerning another child.
OCY removed Child; Child entered a pre-adoptive foster home and referred to the foster mother as “mommy.”
Father participated in services (anger management, domestic violence program, supervised visits, Time Limited Family Reunification) and briefly received overnight visits, but repeatedly relapsed on alcohol and drugs and had probation detentions.
OCY changed permanency goal to adoption in January 2016; visits ended later in 2015 and Child had been in placement over two years at the termination hearing.
Orphans’ court terminated Father’s parental rights under 23 Pa.C.S. § 2511(a) and (b) (decree entered December 9, 2016); Father appealed only the Section 2511(b) best-interest ruling and denial of a motion to compel visitation notes.

Issue	Father’s Argument	OCY / Court’s Argument	Held
Whether termination under §2511(b) was contrary to Child’s needs and welfare	Father: Visits went well; Father and Child share close bond; Child was upset when visits stopped, so termination would harm Child	Court: Although bond exists, Father failed to remedy substance abuse; Child needs permanence and stability in pre-adoptive home; Child showed little adverse effect from ceased visits	Affirmed: §2511(b) favors termination—child’s need for permanence outweighs bond
Whether the court erred denying Father’s motion to compel visitation case notes/summaries	Father: Notes are discoverable and could reveal favorable evidence about parenting and bond; denial prejudiced his defense	Court: Documents were treated as OCY work product but, even if discoverable, notes would be cumulative of testimony that visits went well and would not change outcome	Affirmed (harmless error if any): Denial did not prejudice Father or alter result

In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard of review and deference to trial court findings in termination cases)
In re L.M., 923 A.2d 505 (Pa. Super. 2007) (bifurcated §2511(a)/(b) analysis)
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (bond is a factor among many; court may emphasize child’s safety and stability)
In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (consider continuity and potential harm of severing parent-child bond)
In re Adoption of R.J.S., 901 A.2d 502 (Pa. Super. 2006) (child cannot be kept waiting indefinitely for parent’s progress; permanence requirement)
Drew v. Work, 95 A.3d 324 (Pa. Super. 2014) (harmless error analysis requiring demonstration of prejudice)
Lake Adventure Cmty. Ass'n v. Dingman Tp. Zoning Hearing Bd., 72 A.3d 807 (Pa. Cmwlth. 2013) (explaining that an error is harmless when no prejudice results)