In Re: Adoption of S.R.S. Appeal of: S.A.S. father, 1256 WDA 2016

Child taken into Agency custody at ~3 months old after multiple referrals (concerns: lack of bonding, caregiver issues, a Megan’s Law offender in home); placed with paternal grandparents where she remained.
Parents have longstanding cognitive and untreated mental-health issues; Mother scored in the extremely low intellectual range and does not retain parenting instruction; Father refused or failed to complete recommended treatment and services.
Parents received extensive services (parenting classes, supervised visits, tailored instruction), but over ~34 months visitation never progressed beyond supervised/monitored levels and parenting deficiencies persisted.
Housing and financial instability, poor home maintenance, and inappropriate behaviors during visits (Father) were documented; the Child sometimes resisted visits and showed no distress at Parents’ absence.
Agency filed for involuntary termination July 7, 2015; Orphans’ Court terminated parental rights under 23 Pa.C.S. § 2511(a)(2), (5), (8) and (b) on August 1, 2016; Parents appealed and Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination under 23 Pa.C.S. § 2511(a)(2) is supported	Father: court erred because MFC was an ineffective provider and no alternate individualized plan was offered	Agency/Orphans’ Ct: Parents’ repeated incapacity and failure to remedy causes justify termination	Held: Affirmed — clear and convincing evidence of repeated/continued incapacity and inability/unwillingness to remedy (§ 2511(a)(2))
Whether reasonable services were provided / need for alternate services	Mother: Agency failed to provide additional or alternate services despite known provider–client conflict and Mother’s needs	Agency/Orphans’ Ct: Services were adequate and tailored; parents failed to apply instruction; Agency not required to offer services indefinitely	Held: Affirmed — lack of progress despite extensive services does not excuse termination; alternate services not required here
Whether termination meets child’s best interests under § 2511(b) (bond and welfare)	Mother: termination ignores her bond with Child	Agency/Orphans’ Ct: Bond is weak/loose; Child thrives with grandparents; severance won’t harm Child	Held: Affirmed — primary consideration to Child’s developmental, physical, emotional needs favors termination (no detrimental bond effect)

In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard of review and deference to trial court credibility findings)
In re L.M., 923 A.2d 505 (Pa. Super. 2007) (bifurcated Section 2511(a)/(b) analysis)
In re Geiger, 331 A.2d 172 (Pa. 1975) (three-part test for § 2511(a)(2))
In re R.M.G., 997 A.2d 339 (Pa. Super. 2010) (long-term failure to progress in supervised visits supports termination)
In re A.L.D., Jr., 797 A.2d 326 (Pa. Super. 2002) (agency not required to provide services indefinitely)
In re C.M.S., 884 A.2d 1284 (Pa. Super. 2005) (best-interests inquiry involves love, comfort, security, stability)
In re K.Z.S., 946 A.2d 753 (Pa. Super. 2008) (where no evidence of parent–child bond exists, court may infer none)