Interest of A.G.S. & M.R.S. Appeal of:S.S., father, Interest of A.G.S. & M.R.S. Appeal of:S.S., father No. 1880 WDA 2016

Father (S.S.) and Mother have lengthy histories of drug abuse and incarceration; both children were adjudicated dependent in October 2014 and placed with long‑term foster parents (the Ls).
A.G.S. was born drug‑affected; both children have lived with the foster family for over two years and were reported to be thriving there.
CYS filed petitions to involuntarily terminate parental rights in April 2015 (amended November 2015); evidentiary hearings were held across 2015–2016.
Caseworker and foster‑parent testimony described infrequent father visits, repeated positive drug screens for non‑prescribed controlled substances, failure to complete recommended evaluations and to attend children’s medical appointments.
Trial court found the parental bond limited, the children strongly bonded to foster parents, and that severing the foster bond would be harmful; parental rights were involuntarily terminated under 23 Pa.C.S. § 2511(a)(1), (2), (5) and (b).
Father appealed solely arguing the record lacked competent evidence about the parent–child bond and potential harm from severance; Superior Court affirmed.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (CYS / Trial Court)	Held
Whether termination should be reversed for lack of competent evidence about existence/nature of bond and harm from severance	Record is ‘‘devoid’’ of evidence that no bond exists or that severance would not harm children; father had some prior caretaking and visitation	Caseworker and foster parents provided credible testimony that parent–child bond was limited, children view foster parents as primary caregivers, and severing that strong foster bond would be harmful	Affirmed. Trial court’s factual findings about limited parental bond and strong foster bond were supported; termination under §2511(b) was proper
Whether appellate court should disturb trial court’s credibility findings and fact determinations	Father implicitly urges reweighing of evidence on bond	Appellate deference required: abuse of discretion standard; trial court observed witnesses and made credibility calls	Affirmed. Appellate court deferred to trial court’s credibility findings and did not find abuse of discretion

In re R.J.T., 9 A.3d 1179 (Pa. 2010) (explaining deference to trial court fact‑finding in dependency/termination matters)
In re Adoption of S.P., 47 A.3d 817 (Pa. 2012) (bifurcated §2511(a) then (b) analysis and standard of review)
In re Z.P., 994 A.2d 1108 (Pa. Super. 2010) (bonding analysis may rely on social workers and caseworkers; formal bonding expert not required)
In re Adoption of C.D.R., 111 A.3d 1212 (Pa. Super. 2015) (§2511(b) factors include safety, continuity, and whether parental bond can be severed without harm)
In re B.,N.M., 856 A.2d 847 (Pa. Super. 2004) (child’s right to permanency and proper parenting can supersede parental rights after failure to fulfill duties)
In re Adoption of C.L.G., 956 A.2d 999 (Pa. Super. 2008) (court will not delay child’s permanency hopes indefinitely)