Dcpp v. K.F.-b. and T.P., in the Matter of J.P., A-2969-22

K.F.-B. is the biological mother of J.P.; the New Jersey Division of Child Protection and Permanency (Division) petitioned for termination of her parental rights.
J.P. had resided with her paternal aunt and uncle (M.H. and R.H.) since 2018 and expressed a strong preference to be adopted by them.
Defendant opposed termination, seeking either reunification or an alternative such as kinship legal guardianship (KLG).
The trial court found, after hearing extensive evidence from experts and reviewing the parents' conduct, that all four statutory prongs for termination of parental rights were met.
The father, T.P., executed a surrender of his parental rights and did not participate in the appeal.
The Appellate Division reviewed and affirmed the lower court’s order, concluding that termination was in J.P.'s best interests.

Issue	Plaintiff's Argument (Division)	Defendant's Argument (K.F.-B.)	Held
Whether all statutory prongs for termination of parental rights were met	Division met clear and convincing evidence for all four prongs.	K.F.-B. disputed prongs, argued for KLG/reunification.	All prongs met; affirmation.
Whether defendant’s mental health and actions posed harm to J.P.	Defendant’s conduct risked emotional harm to J.P.; lacked insight.	Actions were protective, not harmful; separation was harmful.	Harm shown, supports termination.
Whether Division made reasonable efforts to reunite family or provide alternatives	Division offered therapy and services; reunification not feasible.	Division did not do enough; KLG appropriate.	Efforts sufficient; KLG not preferable.
Whether termination did more harm than good	Termination promoted J.P.'s well-being and permanency.	Termination would harm J.P.; ongoing visitation required.	Termination favored with continued visitation.

N.J. Div. of Youth & Fam. Servs. v. F.M., 211 N.J. 420 (deference to Family Part findings in parental rights termination)
N.J. Div. of Child Prot. & Permanency v. K.T.D., 439 N.J. Super. 363 (substantial credible evidence standard for appellate review)
N.J. Div. of Youth & Fam. Servs. v. P.P., 180 N.J. 494 (trial court’s factual findings in parental rights cases not disturbed unless wholly unsupportable)
In re Guardianship of J.N.H., 172 N.J. 440 (standard for reviewing factual findings in guardianship proceedings)
N.J. Div. of Youth & Fam. Servs. v. C.S., 367 N.J. Super. 76 (priority for child permanency over prolonged parental reunification attempts)
N.J. Div. of Youth & Fam. Servs. v. F.M., 375 N.J. Super. 235 (parental fitness must be timely for child’s needs)