In Re: Adoption of C.D.R., Appeal of: R.R., 111 A.3d 1212

R.R. appeals Sept. 19, 2014 involuntary termination of her parental rights to her son C.D.R.
CYS filed dependency June 1, 2012; Child adjudicated dependent June 6, 2012; custody briefly with maternal aunt during incarceration.
Mother repeatedly incarcerated from 2012-2013 for probation violations/drug charges; Child not resided with her since then.
Permanency goal changed to adoption Jan. 10, 2014; reunification services ended; petition to terminate filed Feb. 3, 2014.
Orphans’ Court terminated rights under 23 Pa.C.S.A. § 2511(a)(2) and (b); court found inability to remedy conditions and best interests favor permanency.
Mother argues she progressed, complied with services, and should regain custody; appellate standard of review favors trial court findings with deference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion under § 2511(a)(2) and (b).	Mother contends she remedied issues, cooperated, and should not lose parental rights.	CYS argues persistent incapacity and failure to remedy; bond and best-interest factors support termination.	No abuse of discretion; termination affirmed under §§ 2511(a)(2) and (b).

In re T.S.M., 71 A.3d 251 (Pa. 2013) (deference to trial court; development of parental rights analysis)
In re L.M., 923 A.2d 505 (Pa. Super. 2007) (needs and welfare with evidentiary standards for termination)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (abuse of discretion standard in termination decisions; en banc consideration)
In re K.K.R.-S., 958 A.2d 529 (Pa. Super. 2008) (bond analysis as a factor in best interests, not sole determinant)
In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (bond considerations and permanency balance in § 2511(b))