In the Interest of: M.J.C., a Minor, In the Interest of: M.J.C., a Minor No. 3168 EDA 2016

Background

Mother (C.C.) had two sons: M.J.C. (b. 2007) and S.P.R. (b. 2015). DHS removed the children from Mother on August 5, 2015 after incidents including domestic violence and an event where infant S.P.R. stopped breathing while left alone.
The trial court adjudicated the children dependent on September 30, 2015; a CUA developed a Single Case Plan (SCP) requiring domestic violence programming, mental-health treatment, parenting classes (ARC), housing stabilization, and regular visits.
Over 2015–2016 Mother inconsistently attended visits, failed to complete parenting classes, intermittently engaged in mental-health care, and lacked stable suitable housing. Some programs were completed (healthy relationships, domestic violence) but parenting and consistent treatment were not.
DHS filed petitions to involuntarily terminate Mother’s parental rights on August 24, 2016; the termination hearing occurred September 8, 2016.
The trial court terminated Mother’s parental rights under 23 Pa.C.S. § 2511(a)(1), (2), (5), (8) and (b). The Superior Court affirmed, focusing analysis on § 2511(a)(8) and § 2511(b).

Issues

Issue	Mother's Argument	DHS/Respondent Argument	Held
Whether § 2511(a)(8) grounds were proven (12+ months removed; conditions persist; termination serves child)	Mother: She remedied conditions (employed, has housing, sober, completed DV and healthy relationships programs)	DHS: Children removed >12 months; Mother lacked stable housing, failed to complete parenting/mental-health objectives and was inconsistent with visits	Held: Affirmed. Children removed >12 months; conditions (deficient parenting, unstable housing, inconsistent engagement) persisted; termination serves children’s needs and welfare
Whether § 2511(b) (best interests, bond analysis) supports termination	Mother: Strong bond with children; DHS failed to reasonably accommodate visits so bond could be strengthened	DHS: Witness testified children have stronger bonds with pre‑adoptive foster parents; M.J.C. exhibited parentified role; termination would not cause irreparable harm	Held: Affirmed. Court found friendly relationship but not parent/child bond with Mother; children bonded to foster parents; termination in children’s best interests
Whether trial court improperly ignored Mother’s post‑petition efforts	Mother: Recent compliance and program completion should preclude termination	DHS: For (a)(8) and (b) analysis, continued conditions and past noncompliance govern; post‑petition efforts insufficient or too recent	Held: Affirmed. Post‑petition/late efforts do not preclude termination under § 2511(a)(8)/(b) and were insufficient to change outcome
Whether trial court erred procedurally in record/credibility findings	Mother: Challenges trial court’s credibility findings and contends DHS didn’t provide reasonable reunification efforts	DHS: Trial court credited CUA/DHS witness testimony; Mother failed to raise reasonable‑efforts claim at hearing; credibility determinations entitled to deference	Held: Affirmed. Appellate court defers to trial court credibility and found no abuse of discretion

Key Cases Cited

In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard of review and deference to trial court credibility in termination cases)
In re Adoption of R.J.S., 901 A.2d 502 (Pa. Super. 2006) (§ 2511(a)(8) does not require evaluation of parent’s willingness/ability to remedy conditions)
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (§ 2511(b) best‑interest factors include bond, stability, and continuity)
In re D.C.D., 105 A.3d 662 (Pa. 2014) (reasonable reunification‑efforts issue does not necessarily preclude termination under certain subsections)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (court need only agree with any one subsection of § 2511(a) plus § 2511(b) to affirm termination)
In re K.Z.S., 946 A.2d 753 (Pa. Super. 2008) (where no evidence of parent–child bond exists, court may infer no bond)