In Re: F.B.-G., a minor, Appeal of: S.R.G., In Re: F.B.-G., a minor, Appeal of: S.R.G. No. 1325 WDA 2016

Child born January 2014; Children, Youth and Families (CYF) first involved with family in 2010 for Mother’s mental-health, substance-use, domestic-violence history, and unstable housing.
Child briefly returned to Mother after birth in January 2014 with in‑home services; Mother became unreachable and Child entered foster care under emergency protective custody in May 2014 and was adjudicated dependent in August 2014.
CYF created Family Service Plan (FSP) goals for Mother (stable housing, financial stability, mental‑health treatment, regular visitation); Mother repeatedly experienced homelessness, evictions, utility/rent problems, and inconsistent visitation.
Psychological evaluations showed Mother positive in interactions with Child but a history of chronic instability, poor judgment, financial mismanagement, and prior schizoaffective diagnosis (with some history of inconsistent symptom reporting); evaluator and foster‑care workers described Child’s primary attachment to foster mother.
CYF petitioned to involuntarily terminate parental rights (filed Feb 2016, amended July 2016); trial court terminated Mother’s rights on August 24, 2016; Mother appealed.

Issue	Mother’s Argument	CYF/Defendant’s Argument	Held
Whether grounds for involuntary termination existed under 23 Pa.C.S. §2511(a)(2) (and (5),(8))	Mother conceded incomplete FSP completion but argued she made progress: had housing at hearing, some mental‑health evaluations showed no treatment needed, positive parent‑child interactions, transportation issues caused missed visits	Mother repeatedly failed to remedy chronic instability (housing, finances), missed visits, and has incapacity/behavior that will not be remedied within a reasonable time	Court affirmed termination under §2511(a)(2): clear and convincing evidence Mother lacks parental capacity and cannot remedy conditions in reasonable time
Whether termination satisfies child’s developmental, physical, and emotional needs under §2511(b)	Mother stressed positive interactions and bond; evaluator suggested some continued contact would benefit Child	Child has a strong, primary attachment to foster mother; foster placement meets Child’s needs; Mother’s instability threatens Child’s need for permanency and stability	Court held termination met §2511(b): severing rights will not cause permanent emotional harm and serves Child’s best interests

In re R.J.T., 9 A.3d 1179 (Pa. 2010) (appellate deference to trial court factfinding and credibility in termination cases)
In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (standards for reviewing termination of parental rights)
In re T.S.M., 71 A.3d 251 (Pa. 2013) (focus on child’s developmental, physical and emotional needs under §2511(b))
In re K.M., 53 A.3d 781 (Pa. Super. 2012) (emotional needs include love, comfort, security, stability)
In re K.Z.S., 946 A.2d 753 (Pa. Super. 2008) (bonding analysis and emphasis on child safety and permanency)