In the Interest of: Z.E.A.F., a Minor, In the Interest of: Z.E.A.F., a Minor No. 887 EDA 2017

Child was adjudicated dependent after incidents including Mother’s drug use, evictions, and an injury to the Child while unsupervised; Father did not reside with Child and had a history of drug-related convictions.
Father was given a Single Case Plan (SCP): random drug screens, maintain supervised weekly visits, and cooperate with CEU/CUA; he missed appointments and failed to comply with CEU requirements.
Child was removed from parental care for more than 12 months and has lived with paternal aunt (guardian) since August 2015; the aunt provides a stable, nurturing home and Child is thriving.
DHS filed to terminate Father’s parental rights; the trial court terminated under 23 Pa.C.S. § 2511(a)(1), (2), (5), (8) and (b) and changed permanency goal to adoption.
Father appealed, arguing he was close to completing SCP goals and asserting an existing parent–child bond; appellate review is for clear-and-convincing evidence and deference to trial-court credibility findings.

Issue	Father’s Argument	DHS/Respondent’s Argument	Held
Whether termination under §2511(a)(8) was supported	Father: He was close to achieving SCP goals and thus should not be terminated	DHS: §2511(a)(8) focuses on whether conditions that led to removal persist after 12+ months, not on belated remedial efforts	Court: Affirmed termination under §2511(a)(8); Father’s near-completion was immaterial to (a)(8) because conditions persisted over required period
Whether termination met §2511(b) (best interests)	Father: There is a meaningful bond between him and Child; termination would harm Child emotionally	DHS: Child is thriving in stable home; bond was not meaningfully developed due to Father’s missed visits; best interests favor permanence with guardian	Court: Affirmed that termination is in Child’s best interests under §2511(b); credited CUA testimony that bond was not sufficiently developed and Child’s needs were met by guardian

In Interest of H.K., 161 A.3d 331 (Pa. Super. 2017) (standard of appellate review in termination cases)
In re K.H.B., 107 A.3d 175 (Pa. Super. 2014) (petitioner must prove termination grounds by clear and convincing evidence)
In re B.L.W., 843 A.2d 380 (Pa. Super. 2004) (appellate court may affirm on any valid subsection of §2511(a))
In re Adoption of M.E.P., 825 A.2d 1266 (Pa. Super. 2003) (elements required for termination under §2511(a)(8))
In re A.R., 837 A.2d 560 (Pa. Super. 2003) (§2511(a)(8) sets 12‑month period to remedy conditions)
In re Adoption of T.B.B., 835 A.2d 387 (Pa. Super. 2003) (court need not evaluate current willingness to remedy conditions for (a)(8))
In re Adoption of C.L.G., 956 A.2d 999 (Pa. Super. 2008) (distinction between focus of §2511(a) on parent and §2511(b) on child)
In re T.S.M., 71 A.3d 251 (Pa. 2013) (primary consideration under §2511(b) is child’s developmental, physical, and emotional needs and the effect of severing parental bond)
In re K.M., 53 A.3d 781 (Pa. Super. 2012) (trial court may rely on social-worker observations; existence of a bond does not preclude termination)
In re Adoption of L.B.M., 161 A.3d 172 (Pa. 2017) (noting limits to K.M. on other grounds)