In the Interest of: J.V.S., a Minor, In the Interest of: J.V.S., a Minor No. 335 EDA 2017

DHS removed five children from Parents' home after an October 2014 home visit revealed deplorable, bug‑infested conditions, lack of immunizations, medical needs (including a child with a feeding tube), truancy, and prior safety concerns dating to 2006 and a 2009 child fatality in the home.
The children were adjudicated dependent; DHS set reunification goals and required parents to clean the home, attend services, obtain housing, complete mental‑health treatment, and participate in a Parenting Capacity Evaluation (PCE).
Father completed some parenting classes and attended limited mental‑health sessions, but failed to complete treatment documentation, secure stable housing, participate in required medical training for the medically fragile child, and consistently cooperate with medical consents and appointments.
The PCE and evaluator concluded Father lacked capacity to provide safety or permanency due to minimization/denial of prior events and ongoing visitation/engagement problems.
DHS petitioned to involuntarily terminate Father’s parental rights under 23 Pa.C.S. § 2511(a)(1),(2),(5),(8) and (b); the court found clear and convincing evidence to terminate and changed the children’s permanency goal to adoption.
Father appealed, arguing insufficient evidence under § 2511(a) and lack of analysis under § 2511(b); the Superior Court affirmed.

Issue	Father’s Argument	DHS/ GAL / Trial Court Argument	Held
Whether §2511(a)(2) termination was supported by clear and convincing evidence of repeated and continued incapacity/neglect that cannot be remedied	Father argued he had begun addressing problems (housing search, mental health) before the termination petition and met most plan goals, so incapacity was not repeated or irremediable	DHS and court relied on long history (since 2006), severe neglect indicators (unsafe home, medical neglect, truancy), Father’s inconsistent treatment, housing not secured, failure to engage in medical care and consent, and evaluator opinion that Father lacked capacity	Affirmed: §2511(a)(2) met; Father’s incapacity/neglect caused children to lack essential care and was unlikely to be remedied
Whether §2511(b) best‑interest analysis required a detailed bonding study or evidence on effects of severance	Father claimed DHS presented no testimony on how termination would affect each child emotionally	DHS/GAL/trial court acknowledged some bond but emphasized children’s needs, foster parents’ provision of stability and special care, and Father’s failure to meet emotional, medical, housing, educational needs	Affirmed: termination serves children’s developmental, physical, and emotional needs; absence of formal bond study did not preclude finding termination was in children’s best interests

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 § 2511(a)/(b) analysis)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (affirmance requires agreement with any one subsection of § 2511(a) plus § 2511(b))
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (elements for § 2511(a)(2) termination and scope of incapacity grounds)
In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (bond analysis is one factor; safety and stability may be emphasized)
In re J.L.C., 837 A.2d 1247 (Pa. Super. 2003) (parental responsibility necessary to develop a meaningful bond)
In re Adoption of J.M., 991 A.2d 321 (Pa. Super. 2010) (extent of bond analysis depends on case circumstances)
In re Z.P., 994 A.2d 1108 (Pa. Super. 2010) (no requirement for expert bonding testimony; caseworkers may opine)
In the Matter of the Adoption of A.M.B., 812 A.2d 659 (Pa. Super. 2002) (child’s life and stability cannot be delayed pending parent’s eventual compliance)