In the Interest of: L.J.L.C., a Minor, 700 MDA 2017

Child born August 2015 with neonatal opioid withdrawal; Mother tested positive for opioids before birth and there were concerns about Mother’s mental health, substance use, and domestic violence.
Child remained in NICU; Mother’s contact was sporadic and monitored for safety; Child discharged to Agency custody October 24, 2015 and adjudicated dependent November 9, 2015.
Agency created a reunification plan for Mother addressing mental health, drug treatment, domestic violence, parenting, income, and housing; Mother made only minimal progress over the ensuing 18 months.
Agency filed petitions to terminate parental rights March 2016 (TPR filed Nov. 7, 2016); Father voluntarily relinquished rights March 23, 2017.
Orphans’ Court held evidentiary hearings and terminated Mother’s parental rights under 23 Pa.C.S. § 2511(a)(1) and (b); Superior Court affirmed.

Issue	Mother’s Argument	Agency’s Argument	Held
Whether court abused discretion by not giving proper weight to Mother’s efforts to complete the reunification plan	Mother: she made meaningful progress (counseling, methadone treatment, employment, improved visits) and needed more time	Agency: Mother’s overall compliance was minimal; she failed to complete required treatments, secure housing/income, or complete parenting classes	Affirmed termination under §2511(a)(1): Mother failed to perform parental duties for the relevant period; progress after TPR notice too late
Whether the court erred by failing to give proper weight to Mother–Child bond	Mother: there was a positive bond from visits	Agency: Child is bonded to resource parents who provided daily care; Mother lacks a sufficient bond to outweigh permanency needs	Affirmed under §2511(b): severing Mother’s rights serves Child’s needs for stability and permanence

In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (appellate deference to trial court findings in TPR cases)
In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard for reviewing TPR determinations)
In re M.G., 855 A.2d 68 (Pa. Super. 2004) (trial court credibility determinations entitled to deference)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (affirmance may rest on any one valid subsection of §2511(a))
In re R.N.J., 985 A.2d 273 (Pa. Super. 2009) (clear and convincing evidence standard explained)
In re Z.S.W., 946 A.2d 726 (Pa. Super. 2008) (§2511(a)(1) requires sustained conduct showing failure to perform parental duties)
In re B., N.M., 856 A.2d 847 (Pa. Super. 2004) (definition of parental duties as affirmative obligations)
In re: Adoption of J.M., 991 A.3d 321 (Pa. Super. 2010) (§2511(b) focuses on child’s developmental, physical, and emotional needs)
In re C.M.S., 884 A.2d 1284 (Pa. Super. 2005) (bond analysis includes intangibles like love, comfort, security, and stability)
In re K.Z.S., 946 A.2d 753 (Pa. Super. 2008) (when no evidence of parent-child bond exists, court may infer none)