In the Interest of: K.B. a/k/a K.J.W., a Minor, 1590 EDA 2016

K.B. born January 2014; at birth both mother and child tested positive for controlled substances and DHS substantiated the report.
DHS found the home unsafe (missing walls, ceiling holes, damaged staircase); child taken into protective custody and placed in foster care and later adjudicated dependent.
DHS filed a petition to terminate Mother's parental rights in March 2016; termination hearing occurred April 22, 2016.
Trial court concluded DHS proved grounds for involuntary termination under 23 Pa.C.S. § 2511(a)(2) (repeated/continued incapacity/neglect) and that termination was in the child's best interests under § 2511(b); court changed permanency goal to adoption.
Mother argued she complied with case plan objectives (housing, some visits, negative drug screens, care for herself) and maintained a loving relationship; court found she failed to complete key Family Service Plan goals (random screens, treatment, mental health services), attended only 14 of 21 visits, and was not credible.
The Superior Court affirmed, holding the record contains clear and convincing evidence supporting termination under § 2511(a)(2) and that severance would not cause long-term harm to the child, who is bonded to the foster mother.

Issue	Mother's Argument	DHS/Trial Court Argument	Held
Whether clear and convincing evidence supported involuntary termination under 23 Pa.C.S. § 2511(a)(2)	Mother argued she substantially complied with case plan, maintained visits, obtained housing, tested negative at some screens, and loves the child	Mother failed to complete random drug screens, drug/alcohol and mental health treatment, and was inconsistent in visits; these failures show continued incapacity/neglect that cannot be remedied	Affirmed: § 2511(a)(2) satisfied by clear and convincing evidence
Whether termination served the child’s developmental, physical, and emotional needs under § 2511(b)	Mother contended the court failed to give primary consideration to child’s needs and the parental bond	Evidence showed child is bonded to foster mother, comfortable and well cared for; child would not suffer long-term harm from termination	Affirmed: termination is in child’s best interests under § 2511(b)

In re T.S.M., 71 A.3d 251 (Pa. 2013) (courts must consider emotional needs and the parent–child bond under § 2511(b))
In re Adoption of G.L.L., 124 A.3d 344 (Pa. Super. 2015) (standard of review and burden of proof for termination appeals)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (affirmance may rest on any one subsection of § 2511(a))
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (elements required for § 2511(a)(2) termination)
In re A.L.D., 797 A.2d 326 (Pa. Super. 2002) (parent must make diligent efforts toward assuming parental responsibilities; too-late cooperation may be rejected)
In re Matsock, 611 A.2d 737 (Pa. Super. 1992) (need to assess both tangible and intangible aspects of child’s needs when considering termination)