In the Interest of: J.G., a Minor, 907 EDA 2016

Mother had three children at issue: B.H. (b. 2001), J.H. (b. 2005, has cerebral palsy, deaf, G‑tube dependent), and J.G. (b. 2013, born exposed to cocaine). DHS became involved in 2012 after concerns about drug abuse, medical neglect, truancy, and lack of food.
J.H. and B.H. were adjudicated dependent in February 2012 and placed in foster care; J.G. was placed in foster care at birth (March 2013 adjudication).
The Family Service Plan (FSP) required Mother to obtain drug/alcohol treatment, complete parenting evaluations/classes, attend medical appointments for J.H., participate in supervised visits, and obtain suitable housing. DHS made multiple referrals (ARC, CEU, parenting evaluation) that Mother largely did not complete.
Mother missed numerous medical appointments for J.H., had poor visitation attendance (roughly 40–60% of offered visits), failed to document completion of treatment, and had another child in 2016 born with cocaine withdrawal symptoms.
DHS filed for involuntary termination of parental rights in October 2013 under 23 Pa.C.S. § 2511(a)(1),(2),(5),(8) and (b). After a four‑day hearing, the trial court terminated Mother’s parental rights (Feb. 29, 2016). Mother appealed; the Superior Court affirmed.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (DHS / Trial Court)	Held
Whether termination was supported by clear and convincing evidence under §2511(a) (esp. (a)(2))	Mother argued she made progress toward FSP goals (sobriety, housing, parenting) and could remedy conditions that caused removal	DHS showed repeated noncompliance: ongoing drug use, failure to complete treatment or parenting evaluations, poor visitation, transient/insufficient housing, and failure to take J.H. to medical appointments	Affirmed: clear and convincing evidence supported termination under §2511(a)(2) because Mother’s incapacity/neglect continued and was unlikely to be remedied
Whether the court gave primary consideration to the children’s developmental, physical, and emotional needs under §2511(b)	Mother argued she maintained a bond and the court failed adequately to consider emotional impact of severing the bond	Trial court found children were bonded to pre‑adoptive foster/kinship parents (J.G. since birth; J.H. bonded to medically capable foster mother; B.H. wanted adoption and ceased contact with Mother) and would not suffer irreparable harm from termination	Affirmed: court properly found termination served the children’s needs and welfare under §2511(b)

In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard of review and deference to trial court fact/credibility findings)
In re L.M., 923 A.2d 505 (Pa. Super. 2007) (bifurcated §2511(a)/(b) analysis)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (affirmance requires agreement with any one §2511(a) ground and §2511(b))
In re Adoption of M.E.P., 825 A.2d 1266 (Pa. Super. 2003) (elements required to terminate under §2511(a)(2))
In re A.L.D., 797 A.2d 326 (Pa. Super. 2002) (parental incapacity may include refusal or inability to perform duties; timeliness of remediation matters)
In re C.M.S., 884 A.2d 1284 (Pa. Super. 2005) (intangible factors—love, comfort, security—in §2511(b) analysis)
In re K.Z.S., 946 A.2d 753 (Pa. Super. 2008) (no evidence of bond may permit inference that no bond exists)
In re K.K.R.S., 958 A.2d 529 (Pa. Super. 2008) (bond is one of many §2511(b) factors; does not preclude termination)
In re T.D., 949 A.2d 910 (Pa. Super. 2008) (strong bond balanced against inability to meet child’s needs)
In re Adoption of T.B.B., 835 A.2d 387 (Pa. Super. 2003) (termination must not destroy an existing necessary/beneficial relationship)
In re A.S., 11 A.3d 473 (Pa. Super. 2010) (court may emphasize child safety and stability and weigh foster relationships)
In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (continuity and whether severing bond causes detriment are relevant to §2511(b))