STATE OF NEW JERSEY VS. STANFORD YOUGHÂ (06-04-0402, PASSAIC COUNTY AND STATEWIDE), A-3710-15T3

Background

Division removed two children (Jason, age 8, with Cornelia de Lange Syndrome; Allison, age 6) after recurring unsafe, cluttered, and unhygienic home conditions, including feces smeared on walls, rodent evidence, and unsafe yard/porch conditions.
Parents received extensive services (parenting skills, psychiatric/psychological treatment, hoarding remediation, visitation) over ~4 years; Division attempted reunification but safety, parental insight, and mental-health stability remained concerns.
Defendant displayed persistent lack of insight and accountability (blamed children or others for household conditions); experienced recurrent depression, anxiety, prior opioid dependence, and at least one episode of hallucinations and reported hiding knives in the home.
Children were placed with paternal relatives who sought to adopt; bonding evaluations showed children had strong attachments to both parents and resource families, though attachments to defendant were insecure.
Division filed to terminate parental rights under N.J.S.A. 30:4C-15.1(a); the Family Part found all four statutory prongs satisfied and terminated defendant's parental rights; defendant appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prong (1) (child's safety, health, development endangered) was proven	Division: home conditions and parental mental-health/behavior repeatedly endangered children; removal and continued out-of-home placement show ongoing danger	N.S.: post-2014 improvements and in-home supervised visitation show only housekeeping issues, not danger; court relied on stale evidence	Affirmed: court reasonably credited Division and expert testimony that conditions and parental incapacity endangered children now and foreseeably
Whether prong (2) (parent unwilling/unable to eliminate harm/delay would add harm) was proven	Division: defendant lacked insight, failed to remediate risks despite services; delay would prolong instability and harm	N.S.: engaged in services, employed, improved mental health; should be given time to parent independently	Affirmed: experts and court found defendant unlikely to achieve safe, stable parenting in foreseeable time; delay would harm children needing permanency
Whether prong (3) (reasonable efforts/alternatives) was proven	Division: provided extensive services, hoarding remediation, therapy, visitation; relatives sought adoption, not kinship guardianship	N.S.: contends experts relied on imperfect data and caseworker reports	Affirmed: record shows comprehensive services and no viable alternative to termination given children's need for permanency
Whether prong (4) (termination will not do more harm than good) was proven	Division: children bonded to resource parents and would recover from loss; permanency via adoption outweighs harm of severing parental ties	N.S.: bond with mother is strong and she is improving; termination would cause significant harm, siblings are separated	Affirmed: court balanced bonds, childrens' ages/needs, expert testimony that termination better served long-term interests and permanency; separation risk mitigated by continued frequent contact among resource families

Key Cases Cited

N.J. Div. of Youth & Family Servs. v. F.M., 211 N.J. 420 (2012) (standard and deference for termination under best-interests statute)
N.J. Div. of Youth & Family Servs. v. R.G., 217 N.J. 527 (2014) (appellate review deference to family court credibility findings)
N.J. Div. of Youth & Family Servs. v. M.M., 189 N.J. 261 (2007) (role of expert bonding testimony in permanency decisions)
In re Guardianship of D.M.H., 161 N.J. 365 (1999) (relationship between statutory prongs concerning harm and best interests)
In re Guardianship of K.H.O., 161 N.J. 337 (1999) (prong four balancing: permanence vs. severing biological ties)
N.J. Div. of Youth & Family Servs. v. K.M., 136 N.J. 546 (1994) (dangerous or filthy living conditions support neglect findings)
N.J. Div. of Youth & Family Servs. v. G.L., 191 N.J. 596 (2007) (prong four as a fail-safe; considerations for termination)
N.J. Div. of Youth & Family Servs. v. A.W., 103 N.J. 591 (1986) (best-interests test focus on child's welfare, not which parent is better)
N.J. Div. of Youth & Family Servs. v. L.C., 346 N.J. Super. 435 (App. Div. 2002) (no per se requirement to recuse trial judge who presided over prior abuse-and-neglect proceedings)