In the Interest of: K.C., a Minor, 1125 EDA 2017

Child Ka.C. born with opiates and cocaine in his system in Dec. 2013; both parents incarcerated; child placed in kinship foster care with maternal relatives who are adoptive resources.
Juvenile court adjudicated Ka.C. dependent (Feb. 19, 2014); initial permanency goal reunification, with supervised visits arranged while parents were incarcerated.
Father made little progress; court changed permanency goal as to Father to adoption (Apr. 7, 2016); petitions to terminate parental rights were pending in the orphans’ court.
CYS moved at a Mar. 1, 2017 permanency review to reduce weekly 2.5-hour supervised visits at SCI Graterford to monthly, citing child burden and Father’s restrictive-housing visits behind glass.
Trial court denied CYS’s one-per-month request but ordered temporary reduction while Father remained in restrictive housing: one-hour biweekly visits, increasing to 2.5 hours biweekly (or two-and-a-half hours after return to less restrictive unit) and entered order Mar. 7, 2017.
Father appealed the visitation adjustment; Superior Court quashed appeal for lack of jurisdiction but addressed merits and would have denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused discretion by reducing Father's visitation frequency/duration	Father: reduction to bi-weekly visits (and shortened duration) is contrary to child’s best interests; court erred	CYS/juvenile court: reduction is appropriate given shift toward adoption, visit burdens on a 3-year-old, and Father’s restrictive housing; best interests favor tapering visits	Appeal quashed for lack of jurisdiction; on the merits court would have denied relief and found no abuse of discretion

In re H.S.W.C.-B., 836 A.2d 908 (Pa. 2003) (discusses finality of visitation orders under Adoption Act)
In re J.S.C., 851 A.2d 189 (Pa. Super. 2004) (orders adjusting visitation in dependency are not final appealable orders)
In the Interest of M.B., 674 A.2d 702 (Pa. Super. 1996) (standard for reviewing visitation reductions in dependency: abuse of discretion)
In re L.V., 127 A.3d 831 (Pa. Super. 2015) (distinguishing standards when permanency goal shifts from reunification)
In the Interest of L.T., 158 A.3d 1266 (Pa. Super. 2017) (when goal is adoption, best-interests standard governs visitation reductions)
In the Interest of K.C., 160 A.3d 256 (Pa. Super. 2017) (prior appeal addressing permanency goal change as to Father)