In Re: H.C., a Minor, 1243 MDA 2021

Background

Child H.C., born December 2010, has been in placement since August 2016 and expressed a desire to be adopted by pre‑adoptive foster parents.
Susquehanna County Services for Children and Youth (SCSCY) filed a petition for involuntary termination of Mother’s parental rights on August 21, 2019; Father’s rights were previously terminated and he is not a party to this appeal.
Mother executed a consent to adoption in September 2020 but succeeded in revoking that consent in January 2021; the case proceeded to an involuntary termination hearing held across multiple virtual and one in‑person sessions in 2021.
The trial court entered an amended order terminating Mother’s parental rights on August 31, 2021, citing §2511(a)(2) and containing 18 findings of fact but providing only a one‑sentence dispositive statement and no detailed legal analysis tying facts to the statutory criteria.
Mother appealed, raising sufficiency and best‑interest challenges under 23 Pa.C.S.A. §2511(a)(2) and (b) and arguing the trial court failed to state adequate reasons; the Superior Court found the trial court’s order lacked a comprehensive Rule 1925(a) analysis and remanded for preparation of a detailed opinion.

Issues

Issue	Plaintiff's Argument (SCSCY)	Defendant's Argument (Mother)	Held
Sufficiency under §2511(a)(2): whether record supports termination for repeated/continued incapacity/neglect causing lack of essential parental care	SCSCY: evidence and findings (long placement, lack of contact, unstable housing, relocation) support termination	Mother: SCSCY failed to prove the statutory elements by clear and convincing evidence	Superior Court did not decide merits; remanded because trial court’s order lacked the required detailed analysis to permit meaningful appellate review
Best interests under §2511(b): whether termination serves child’s developmental, physical, emotional needs	SCSCY: termination is in child’s best interest; adoption by foster parents is appropriate and stable	Mother: termination is not proven to be in child’s best interest	Superior Court did not decide merits; remanded for trial court to analyze §2511(b) factors with record references
Adequacy of trial court’s opinion / Rule 1925(a): whether the court sufficiently explained its statutory analysis	SCSCY: findings and conclusions are sufficient to support termination	Mother: order lacked specificity, record citations, and a binding application of law to facts	Court held the order was insufficiently reasoned, lacking comprehensive legal and factual analysis; remand ordered for a full Rule 1925(a) opinion
Validity of appeal from amended order / §5505 notice issue	SCSCY: amended order controls; any modification was permissible	Mother: appealed both orders to preserve rights; raised no objection to lack of notice	Superior Court held appeal lies from August 31 amended order; although §5505 normally requires notice for modification, the amendment was typographical (father’s name) and parties did not object, so appeal proper

Key Cases Cited

In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (standard of review and deference to trial court findings)
In re R.J.T., 9 A.3d 1179 (Pa. 2010) (trial court credibility determinations in termination cases)
In re Adoption of C.M., 255 A.3d 343 (Pa. 2021) (gravity of termination and constitutional dimensions of parental rights)
In re Z.P., 994 A.2d 1108 (Pa. Super. 2010) (clarifying §2511(a)(2) standards and deadlines for remedial efforts)
In re Adoption of J.N.M., 177 A.3d 937 (Pa. Super. 2018) (role of bond analysis under §2511(b) and reliance on social‑work testimony)
Daniels v. Workers’ Compensation Appeal Bd. (Tristate Transport), 828 A.2d 1043 (Pa. 2003) (importance of reasoned articulation by tribunals)
Commonwealth v. Moto, 23 A.3d 989 (Pa. 2011) (trial court must explain rationale in sufficient legal and factual detail)
In re B.J.Z., 207 A.3d 914 (Pa. Super. 2019) (affirmance where competent evidence supports termination despite contrary possible outcome)