In The Interest of K.C., 1579 EDA 2016

Child (born Dec. 2013) has been in Bucks County Children & Youth Agency (Agency) custody since birth; both parents have been incarcerated for most or all of the child's life.
Father is serving multiple sentences, including a 4-to-10 year term (entered Sept. 29, 2014); his earliest realistic release was at least two years after the goal-change hearing; Father filed a PCRA petition but no imminent release was established.
Agency petitioned to change permanency goals; hearing held March 4, 2016; trial court entered an order (Apr. 6, 2016) changing the permanency goal to adoption as to Father but not as to Mother (because Mother's release was imminent).
Trial court found Agency made reasonable efforts at reunification, Father had limited ability to remedy circumstances causing placement (ongoing incarceration, past conduct including conspiring to smuggle contraband while mother was pregnant), and child had been placed longer than 15 of the last 22 months.
Father appealed, arguing the court erred in changing the goal to adoption as to him and (arguably raised later) that the court improperly set different goals for each parent; the court of appeals affirmed, finding waiver as to the latter argument and no abuse of discretion on the merits.

Issue	Father's Argument	Agency/Trial Court Argument	Held
Whether changing permanency goal from reunification to adoption for Father was an abuse of discretion	Court abused discretion; goal change not warranted	Change to adoption was in child's best interests due to continued incarceration, need for permanency, Agency efforts, and statutory factors	Affirmed — no abuse of discretion; goal change proper as to Father
Whether statute or rules preclude different permanency goals for each parent	Father: §6351(e)(1) permits only a goal for the child, so court cannot bifurcate goals between parents	Court: statute and Rule 1608 do not prohibit differing goals tailored to each parent's situation; no controlling precedent for Father's view	Waived on appeal (not preserved); alternatively, meritless — statute does not preclude differing parental goals

In re R.M.G., 997 A.2d 339 (Pa. Super. 2010) (standard for reviewing goal-change decisions; child’s best interests prevail)
In re N.C., 909 A.2d 818 (Pa. Super. 2006) (factors and abuse-of-discretion framework in permanency decisions)
In re C.J.R., 782 A.2d 568 (Pa. Super. 2001) (courts must focus on child's best interests, not parents')
In re A.K., 936 A.2d 528 (Pa. Super. 2007) (affirming goal change to adoption where father incarcerated and future availability uncertain)
In re S.B., 943 A.2d 973 (Pa. Super. 2008) (goal change appropriate despite substantial parental compliance when child’s stability warrants it)
In re A.P., 728 A.2d 375 (Pa. Super. 1999) (parent must meet irreducible minimum parental responsibilities)
In re Adoption of R.J.S., 901 A.2d 502 (Pa. Super. 2006) (child’s need for permanence cannot be subordinated indefinitely to parental hope)
Commonwealth v. Castillo, 888 A.2d 775 (Pa. 2005) (procedural waiver for issues not raised in Rule 1925(b) statement)
Faust v. Walker, 945 A.2d 212 (Pa. Super. 2008) (statutory interpretation rules; unambiguous statutory text controls)