In the Interest of: S.C., Appeal of CYS, 247 A.3d 1097

Background:

Six-week-old S.C. was taken to UPMC Children's Hospital in Nov. 2017 with vomiting blood; exam showed bucket-handle fractures of both legs, oral injuries, and bruising; injuries were diagnosed as non-accidental trauma.
Parents could not provide a plausible explanation for the injuries; CYF obtained emergency custody and placed S.C. with his paternal grandparents, where he remained for ~two years.
In Feb. 2019 both parents pleaded guilty to endangering the welfare of a child; CYF filed a petition in May 2019 seeking involuntary termination of parental rights under 23 Pa.C.S. § 2511(a)(2), (a)(5), (a)(8) and (b).
The trial court's written order denied termination but its Rule 1925 opinion found (a)(2) proven while concluding termination was not in the child’s best interests — creating an analytical inconsistency.
On appeal the Superior Court agreed CYF proved §2511(a)(2) (parents repeatedly refused to explain/accept responsibility and failed adequate anger‑management remediation), found the trial court erred in its §2511(b) analysis (overemphasized parental bond and underconsidered child safety and grandparents’ role), vacated the order, and remanded with instructions to terminate both parents’ rights.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CYF proved grounds to involuntarily terminate under §2511(a)(2)	CYF: Parents repeatedly failed to give plausible explanation or accept responsibility for severe abuse and did not complete recommended treatment; thus child lacks essential parental care	Parents: Argued compliance and bond; challenged sufficiency for termination	Held: Affirmed — clear and convincing evidence supported §2511(a)(2) as to both parents
Whether CYF proved grounds under §2511(a)(5) and §2511(a)(8)	CYF: Child removed >6/12 months; conditions causing removal persist; termination serves child	Parents: Argued compliance efforts and parental bond mitigate need for termination	Held: Court relied on (a)(2); did not need to resolve (a)(5)/(a)(8) expressly
Whether termination is in child’s best interests under §2511(b)	CYF/KidsVoice: Child’s safety, grandparents’ stable, nurturing home, and parents’ failure to remediate outweigh parental bond	Parents: Emphasized attachment to parents and harms from severing bond	Held: Reversed trial court — appellate held trial court abused discretion by overemphasizing parent-child bond and failing to weigh child safety and continuity with grandparents; termination is in S.C.’s best interests
Evidentiary/pretrial rulings (motion to strike pre‑trial statement; witness testimony)	CYF: Trial court erred in partially denying motion and admitting certain testimony	Parents: Testing admissibility/harmless error; testimony relevant	Held: Not addressed on appeal after appellate disposition (issue not decided due to remand instructions)

Key Cases Cited

In re T.S.M., 71 A.3d 251 (Pa. 2013) (standard of review and framework for termination appeals)
In re Z.P., 994 A.2d 1108 (Pa. Super. 2010) (definition of clear and convincing evidence and parental incapacity analysis)
In re C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (best‑interest factors include safety, attachment, stability, and continuity)
In re B.J.Z., 207 A.3d 914 (Pa. Super. 2019) (deference to trial court findings supported by competent evidence)
In re R.J.T., 9 A.3d 1179 (Pa. 2010) (credibility determinations and appellate deference)
In re M.E.P., 825 A.2d 1266 (Pa. Super. 2003) (elements required under §2511(a)(2))
In re A.L.D., 797 A.2d 326 (Pa. Super. 2002) (parental incapacity may include refusal or inability to perform duties)
In re K.K.R.-S., 958 A.2d 529 (Pa. Super. 2008) (bond/attachment analysis in §2511(b) inquiry)
In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (parental bond is one of multiple §2511(b) factors)
In re J.N.M., 177 A.3d 937 (Pa. Super. 2018) (importance of safety, stability, and continuity in best‑interest analysis)