In the Interest of: M.A.C., a Minor, In the Interest of: M.A.C., a Minor No. 223 MDA 2017

Mother (H.C.) appealed the involuntary termination of her parental rights to four children (born 2006–2010) after the Lancaster County Children & Youth Agency petitioned under the Adoption Act.
Children had been in agency placement for 33 months at the time of the termination hearing; the Agency sought termination under 23 Pa.C.S. § 2511(a)(8) with consideration of § 2511(b).
Trial court found Mother made minimal progress: she lacked stable housing and income, had ongoing mental-health and employment issues, and had not remedied the conditions that led to removal within the relevant statutory period.
A psychological bonding/attachment assessment (Dr. Suzanne Ail) found attachments between Mother and Children but stronger bonds with foster/placement parents; the assessor recommended termination despite existing attachments.
Mother argued the conditions had been addressed, challenged the reliability and scope of the bonding evaluation, and contended some contributing factors (mental health, loss of SSI payments) were beyond her control.
The Superior Court applied the abuse-of-discretion standard, deferred to the trial court’s credibility findings, and affirmed the decrees terminating Mother’s parental rights and changing permanency goals to adoption.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (Agency/Trial Court)	Held
Whether evidence supported termination under § 2511(a)(8) (conditions continuing after 12+ months)	Mother: Conditions (truancy, chaos, alleged drug use, domestic violence) had been addressed and she had made progress.	Agency/Trial Ct: Children were removed >12 months; Mother failed to remedy conditions despite Agency efforts; Children had been placed 33 months.	Held: Affirmed — § 2511(a)(8) satisfied; Mother’s efforts were minimal and conditions persisted.
Whether termination was in children’s best interests under § 2511(b) (bonds, developmental/ emotional needs)	Mother: Bonding evaluation was flawed/biased (didn't account for disparity in time with foster parents, improperly considered Mother’s case-plan progress and best-interests factors). Also, housing/income and mental health issues were beyond her control.	Agency/Trial Ct: While attachments to Mother existed, bonds with foster parents were stronger; severing would serve children’s need for stability and permanence.	Held: Affirmed — § 2511(b) satisfied; bonds with foster families outweighed Mother’s attachments and termination served children’s welfare.

In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (appellate review: defer to trial court credibility in dependency/termination cases)
In re R.N.J., 985 A.2d 273 (Pa. Super. 2009) (burden on petitioner is clear and convincing evidence)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (satisfaction of one § 2511(a) subsection plus § 2511(b) suffices for termination)
In re A.R., 837 A.2d 560 (Pa. Super. 2003) (§ 2511(a)(8) requires a 12-month period and evaluation whether conditions continue)
In re I.J., 972 A.2d 5 (Pa. Super. 2009) (reunification must be imminent; children’s need for permanence limits parental remediation time)
In re C.M.S., 884 A.2d 1284 (Pa. Super. 2005) (§ 2511(b) focuses on child’s developmental, physical, emotional needs and nature of parent-child bond)
In re Z.P., 994 A.2d 1108 (Pa. Super. 2010) (courts must assess whether termination would destroy an existing, necessary, beneficial relationship)
In re T.S.M., 71 A.3d 251 (Pa. 2013) (consider strength of bond with potential adoptive/foster parents)
In re Adoption of C.L.G., 956 A.2d 999 (Pa. Super. 2008) (distinguishes focus of § 2511(a) on parent and § 2511(b) on child)