In Re: A.J.B., A Minor, Appeal of: K.B., In Re: A.J.B., A Minor, Appeal of: K.B. No. 1387 WDA 2016

Child (b. Dec. 2014) came into OCYF custody at birth after Mother and the newborn tested positive for opiates; Child placed with paternal grandparents.
Father had extensive criminal history and was incarcerated for offenses with release dates no earlier than Oct. 2019 (minimum) and Oct. 2023 (maximum); visits were supervised and limited after incarceration.
OCYF filed petitions to involuntarily terminate parental rights (April 15, 2016); hearing held August 19, 2016; trial court terminated Father’s rights under 23 Pa.C.S. § 2511(a)(2), (5), (8) and (b).
Experts (Dr. Bernstein and Dr. O’Hara) evaluated Father/child and grandparents/child; findings: Father interacted affectionately but exhibited anger issues and personality concerns; grandparents provided a stable, secure, pre‑adoptive home with a strong bond to Child.
Father argued a strong bond existed and he completed a parenting program, urging preservation of parental rights to maintain future contact; trial court concluded termination served Child’s developmental, physical and emotional needs and welfare.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether terminating Father’s parental rights satisfies the child’s needs and welfare under 23 Pa.C.S. § 2511(b) given claimed bond	Father: He maintained consistent supervised visits, completed parenting program, and has a strong bond with Child; termination would jeopardize future contact	OCYF/Trial Ct: Bond is limited by incarceration and supervision; experts endorsed grandparents’ stable, nurturing, pre‑adoptive placement; Father’s temperament/anger and long incarceration weigh against Child’s best interests	Court affirmed termination: severing rights would not produce extreme emotional harm; Child’s needs and welfare are best served by termination and permanency with grandparents

In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (deference to trial court factual findings and credibility in TPR cases)
In re R.J.T., 9 A.3d 1179 (Pa. 2010) (standard for abuse of discretion review in parental‑termination appeals)
In re T.S.M., 71 A.3d 251 (Pa. 2013) (bifurcated analysis under § 2511: first parental conduct, then child’s needs and welfare)
In re L.M., 923 A.2d 505 (Pa. Super. 2007) (discussion of § 2511(b) and bond analysis)
In re Adoption of T.B.B., 835 A.2d 387 (Pa. Super. 2003) (affirm where competent evidence supports trial court despite contrary record support)
In re K.M., 53 A.3d 781 (Pa. Super. 2012) (emotional needs include love, comfort, security, and stability in § 2511(b) analysis)
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (bond is one of several factors; court may emphasize child’s safety and stability with foster/adoptive caregivers)