In re K.J., 27 A.3d 236

DHS became involved in Oct. 2008 via GPS alleging mother's drug use and supervision failures.
In Apr. 2009, DHS received another GPS report; by Apr. 3, 2009, Child and brother were placed in kinship care with Maternal Aunt after protective custody Order.
Child adjudicated dependent; DHS established parental goals requiring drug treatment, parenting classes, visits, and mental health treatment.
Mother repeatedly refused or failed to comply with drug treatment and other FSP goals; visits were irregular or non-existent.
Child moved to North Carolina under ICPC with Maternal Cousin in Apr. 2010; Mother had minimal visitation and did not sustain contact.
DHS petitioned for permanent legal custody in Aug. 2010; evidentiary hearing held Oct. 13, 2010 in Mother's absence; court granted permanent legal custody to Maternal Cousin and husband.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there abuse of discretion in granting permanent legal custody to a relative	Mother argues she complied with FSP goals and that visitation and Dauphin program should satisfy goals.	Court found extensive noncompliance and longstanding instability; permanency was in Child's best interest.	No abuse; best interests supported permanent legal custody to Maternal Cousin
Did denial of continuance violate due process due to illness claim	Mother contends illness prevented participation and warranted continuance.	Trial court exercised discretion; continuance not warranted; bifurcation offered but declined.	No due process violation; no abuse of discretion

In re A.K., 906 A.2d 596 (Pa. Super. 2006) (establishes broad discretion on permanency findings and child-focused standard)
In re B.S., 861 A.2d 974 (Pa. Super. 2004) (guides permanency goal determinations and relative placement considerations)
In re: J.Y., 754 A.2d 5 (Pa. Super. 2000) (waiver principle for due process challenges not raised below)