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In the Int. of: L.G., Appeal of: C.G. - Parental Rights Termination

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Filed March 17th, 2026
Detected March 17th, 2026
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Summary

The Pennsylvania Superior Court affirmed the termination of parental rights for C.G. concerning her two minor sons, L.G. and N.G. The appeal stemmed from concerns regarding the mother's mental health and drug use impacting her ability to parent and maintain the children's safety.

What changed

The Pennsylvania Superior Court, in a non-precedential decision, affirmed the termination of parental rights for C.G. (Mother) to her two minor sons, L.G. and N.G. The appeal, docketed under Nos. 1191 WDA 2025 and 1192 WDA 2025, originated from orders entered on August 27, 2025, by the Court of Common Pleas of Allegheny County. The termination was based on concerns raised by the Allegheny County Office of Children, Youth and Families (CYF) regarding the Mother's mental health and drug use, which impacted her ability to ensure the children's safety, including observations of a child's injury and inconsistent explanations from the Mother.

This decision represents a final judicial determination on the parental rights of C.G. For legal professionals involved in child welfare cases, this ruling underscores the importance of thorough documentation of parental fitness, including mental health and substance abuse issues, and the agency's adherence to established procedures for child protection. While this is a non-precedential decision, it reinforces the legal standards for involuntary termination of parental rights in Pennsylvania. No specific compliance actions are required for regulated entities beyond adherence to existing child welfare and family law statutes and regulations.

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                  by Panella](https://www.courtlistener.com/opinion/10809928/in-the-int-of-lg-appeal-of-cg/#o1)

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March 17, 2026 Get Citation Alerts Download PDF Add Note

In the Int. of: L.G., Appeal of: C.G.

Superior Court of Pennsylvania

Combined Opinion

                        by [Jack A. Panella](https://www.courtlistener.com/person/8243/jack-a-panella/)

J-S01019-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

IN THE INTEREST OF: L.G., A MINOR : IN THE SUPERIOR COURT OF
: PENNSYLVANIA
:
APPEAL OF: C.G., MOTHER :
:
:
:
:
: No. 1191 WDA 2025

Appeal from the Order Entered August 27, 2025
In the Court of Common Pleas of Allegheny County Orphans' Court at
No(s): CP-02-AP-0000060-2024

IN THE INTEREST OF: N.G., A : IN THE SUPERIOR COURT OF
MINOR : PENNSYLVANIA
:
:
APPEAL OF: C.G., MOTHER :
:
:
:
: No. 1192 WDA 2025

Appeal from the Order Entered August 27, 2025
In the Court of Common Pleas of Allegheny County Orphans' Court at
No(s): CP-02-AP-0000061-2024

BEFORE: BOWES, J., PANELLA, P.J.E., and STEVENS, P.J.E.*

MEMORANDUM BY PANELLA, P.J.E.: FILED: March 17, 2026

C.G. (“Mother”) appeals from the August 27, 2025 orders that

involuntarily terminated her parental rights to her sons, L.G., born in July


  • Former Justice specially assigned to the Superior Court. J-S01019-26

2017, and N.G., born in August 2019 (collectively, “the Children”).1 After

review, we affirm.

We glean the following factual and procedural history from the certified

record. The Allegheny County Office of Children, Youth and Families (“CYF”

or “the Agency”) received a referral on June 13, 2022, raising “overall

concerns that [Mother’s] mental health and drug use were impacting her

ability to parent and maintain the [C]hildren’s safety.” N.T., 8/8/25, at 53.

The court set forth the following facts giving rise to the Children’s emergency

custody placement on June 23, 2022.

...

  1. On June 17, 2022, CYF intake caseworker Ramona Singleton
    made a home visit. She observed Mother exhibit behavior that
    was somewhat bizarre. For example, [N.G.] had a black eye that
    appeared to be a couple of days old. Mother explained that [L.G.]
    caused it, stating first that [L.G.] hit [N.G.] with a cell phone and
    then that [L.G.] hit [N.G.] with some sort of pump. Mother
    showed the worker a video of [L.G.] apologizing to [N.G.] and
    explained that she “tapes everything” because she is a good mom.

  2. On June 20, 2022, Ms. Singleton returned for another home
    visit which raised concerns for Mother’s level of supervision of the
    Children. Mother was seated in the home for her meeting with
    the worker and frequently read passages from her Bible. The
    Children were quite active, and the worker felt it necessary to
    intervene three times to alert Mother to go after the Children
    because they had gotten out of the family’s yard.


1 By the same orders, the court additionally involuntarily terminated the
parental rights of L.G.’s father, K.H., and N.G.’s father, K.B., as well as any
unknown father as to N.G. Neither K.H., K.B., nor any unknown father filed
an appeal or participated in the instant appeals.

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J-S01019-26

  1. On June 23, 2022, CYF caseworker Leria Felix and a CYF
    trainee made another home visit. Upon arrival, Mother could be
    heard yelling from inside the home. The caseworker was
    eventually able to enter the home with police assistance after
    Mother repeatedly slammed the door in her face. Police . . . were
    . . . en route to the residence prior to the caseworker’s arrival.

  2. Once inside the home, the caseworker observed furniture
    blocking doorways and an odor of animal feces and urine. There
    were feces on the floor in one room. [N.G.] showed the CYF
    trainee a magazine to a handgun. A handgun was later located in
    the Children’s bedroom . . . .

  3. Mother’s behavior was escalated and erratic during this visit.
    Among other things, she appeared preoccupied with religion. She
    also made sexual comments to the police.

  4. CYF obtained [emergency custody] due to the presence of the
    gun. The routine placement physical for the Children revealed
    three concerns about marks on [N.G.]’s body. First, he had more
    bruises than are typical for a child his age. Second, he had an
    oval scar on his right upper chest that is likely from a burn. Third,
    he had patterned lateral marks on his right forearm consistent
    with being grabbed with excessive force by an adult. None of
    these marks required any medical follow-up.

...

Agency Exhibits 1 & 2, Orders of Adjudication and Disposition, 7/25/22, at ¶¶

12-17 (cleaned up); see also N.T., 8/8/25, at 53-55, 107. The Agency placed

the Children, then almost five and three years old, in foster care. See N.T.,

8/8/25, at 55.

The court adjudicated the Children dependent on July 25, 2022. At that

time, the court provided for supervised visitation with Mother and established

the Children’s respective permanency goals as reunification. See Agency

Exhibits 1 & 2, Orders of Adjudication and Disposition, 7/25/22. In

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J-S01019-26

conjunction with the court’s directives, the Agency instituted a service plan

with goals focused on drugs and alcohol, mental health, parenting skills,

visitation, housing, and addressing outstanding criminal matters. See N.T.,

8/8/25, at 57.

Mother is diagnosed with an adjustment disorder with mixed anxiety and

depressed mood, as well as, historically, cannabis abuse. See id. at 13-14.

The record indicates that she used marijuana regularly without a valid medical

marijuana card. See id. at 13. Moreover, Mother has an extensive criminal

history. Between September of 2022, and December of 2024, she was

criminally charged in four separate incidents with, inter alia, simple assault

and resisting arrest, to which she pleaded guilty. See Agency Exhibit 4.

Mother was sentenced to probation and, ultimately, one to three months’

incarceration, which she served from December 2024, until March 2025. See

id. Additionally, at the time of the subject hearing, multiple charges stemming

from January 2024, including driving under the influence, remained pending

against Mother, along with an outstanding bench warrant for her arrest. See

N.T., 8/8/25, at 57-58.

Further, the record reveals that the Children suffer from behavioral and

mental health issues and have each been diagnosed with, inter alia, attention

deficit hyperactivity disorder (“ADHD”) and an attachment disorder. See id.

at 32-33, 72-73, 77-78, 88, 113, 116. According to Dr. Eric Bernstein, who

conducted individual and interactional evaluations of the family, including

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J-S01019-26

several interactional evaluations involving the Children, the Children “[have

been challenging and at times aggressive, destructive, and allegedly even

inappropriate with their touch.” Id. at 29. The Children are prescribed

medication and participate in individual therapy, among other programs. See

id. At the time of the subject proceeding, L.G., then eight years old, had just

completed a one-month partial hospitalization program as a result of behavior

involving playing with the stove and a lighter and was expected to resume

weekly individual therapy and family-based services. See id. at 72-73, 88.

As a result of these issues, the Children were placed in multiple foster

homes throughout their dependencies. See id. at 28-29, 72. At the time of

the subject hearing, the Children, who were eight and nearly six years old,

were placed in separate foster homes, neither of which were pre-adoptive.

See id. at 70-72, 75-77. Importantly, the Children desired to be reunified

with Mother. See id. at 17, 24, 45, 142-43.

The court held permanency review hearings at regular intervals from

November 2022, through June 2025. Mother’s compliance and overall

progress vacillated between moderate and minimal throughout the Children’s

dependency proceedings. Although she largely maintained moderate

compliance and progress from January 2024, through November 2024, her

adherence regressed to minimal between February 2025 and June 2025. See

Agency Exhibits 1 & 2.

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J-S01019-26

Contemporaneously, on July 2, 2024, the Agency filed petitions for the

involuntary termination of Mother’s parental rights to the Children pursuant

to 23 Pa.C.S.A. § 2511(a)(2), (5), (8), and (b). The orphans’ court held a

hearing on August 8, 2025, at which time the Children were eight and nearly

six years old, respectively.2 The Agency presented the testimony of its

caseworker, Amanda Frank, and Dr. Bernstein, who was accepted by the court

as an expert in forensic psychology. Notably. Dr. Bernstein recognized that a

bond exists between Mother and the Children, but specified that it is not

strong. See N.T., 8/8/25, at 37-38. Further, Dr. Bernstein opined that to the

Children would not suffer “extreme emotional consequences” if Mother’s

parental rights were terminated. See id. at 46-47. The Agency additionally

proffered numerous exhibits which were admitted without objection. Mother

was represented by counsel and testified on her own behalf via telephone.

By orders dated August 12, 2025, and entered on August 27, 2025, the

orphans’ court involuntarily terminated Mother’s parental rights to the

Children pursuant to 23 Pa.C.S.A. § 2511(a)(2), (8), and (b). On September


2 Frank McWilson, Esquire, represented the Children’s legal interests during

the proceeding. See Orders, 8/16/24 (appointment orders). As such, the
court complied with 23 Pa.C.S.A. § 2313(a), as interpreted by the High Court.
See In re Adoption of L.B.M., 161 A.3d 172, 180 (Pa. 2017) (footnote
omitted). Mr. McWilson did not file a brief on behalf of the Children in this
appeal; however, during the subject proceeding, he advocated for the court
to deny the involuntary termination petitions. See N.T., 8/8/25, at 142-43.
We note that the Children were not represented by a guardian ad litem during
the hearing.

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J-S01019-26

23, 2025, Mother timely filed notices of appeal, along with concise statements

of errors complained of on appeal pursuant to Pa.R.A.P. 1925(a)(2)(i) and (b),

which we consolidated sua sponte on October 22, 2025. In response, the

orphans’ court filed a Rule 1925(a) opinion on October 17, 2025, referencing

its reasoning placed on the record and in open court on August 12, 2025. See

N.T., 8/12/25, at 6-25.

On appeal, Mother raises the following issues for our review:

  1. Did the [orphans’] court abuse its discretion and/or err as a
    matter of law in granting the petition to involuntarily terminate
    Mother’s parental rights pursuant to 23 [Pa.C.S.A. §] 2511(a)(2)
    and (8)?

  2. Did the [orphans’] court abuse its discretion and/or err as a
    matter of law in concluding that CYF met its burden of proving by
    clear and convincing evidence that termination of Mother’s
    parental rights would best serve the needs and welfare of the
    [Children] pursuant to 23 [Pa.C.S.A. §] 2511(b)?

Mother’s Brief at 8.

Our standard of review in this context is well-established:

In cases concerning the involuntary termination of parental rights,
appellate review is limited to a determination of whether the
decree of the termination court is supported by competent
evidence. When applying this standard, the appellate court must
accept the trial court’s findings of fact and credibility
determinations if they are supported by the record. Where the
trial court’s factual findings are supported by the evidence, an
appellate court may not disturb the trial court’s ruling unless it
has discerned an error of law or abuse of discretion.

An abuse of discretion does not result merely because the
reviewing court might have reached a different conclusion or the
facts could support an opposite result. Instead, an appellate court
may reverse for an abuse of discretion only upon demonstration
of manifest unreasonableness, partiality, prejudice, bias, or ill-

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J-S01019-26

will. This standard of review reflects the deference we pay to trial
courts, who often observe the parties first-hand across multiple
hearings.

In considering a petition to terminate parental rights, a trial court
must balance the parent’s fundamental right to make decisions
concerning the care, custody, and control of his or her child with
the child’s essential needs for a parent’s care, protection, and
support. Termination of parental rights has significant and
permanent consequences for both the parent and child. As such,
the law of this Commonwealth requires the moving party to
establish the statutory grounds by clear and convincing evidence,
which is evidence that is so clear, direct, weighty, and convincing
as to enable a trier of fact to come to a clear conviction, without
hesitance, of the truth of the precise facts in issue.

Interest of M.E., 283 A.3d 820, 829-30 (Pa. Super. 2022) (internal citations

and quotation marks omitted).

The involuntary termination of parental rights is governed by section

2511 of the Adoption Act, which calls for a bifurcated analysis that first focuses

upon the “eleven enumerated grounds” of parental conduct that may warrant

termination. Id. at 830; see also 23 Pa.C.S.A. § 2511(a)(1)-(11). If the

orphans’ court determines the petitioner has established grounds for

termination under one of these subsections by “clear and convincing

evidence,” the court then assesses the petition pursuant to section 2511(b),

which focuses upon the child’s developmental, physical, and emotional needs

and welfare. In re T.S.M., 71 A.3d 251, 267 (Pa. 2013); see also 23

Pa.C.S.A. § 2511(b). This Court need only agree with the trial court’s

determination as to any one subsection of Section 2511(a), in addition to

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J-S01019-26

Section 2511(b), in order to affirm termination. See In re K.R., 200 A.3d

969, 979 (Pa. Super. 2018) (en banc).

We analyze the decrees involuntarily terminating Mother’s parental

rights to Children pursuant to Section 2511(a)(2) and (b),3 which provide as

follows:

(a) General rule.--The rights of a parent in regard to a child may
be terminated after a petition filed on any of the following
grounds:

...

(2) The repeated and continued incapacity, abuse, neglect
or refusal of the parent has caused the child to be without
essential parental care, control or subsistence necessary for
his physical or mental well-being and the conditions and
causes of the incapacity, abuse, neglect or refusal cannot or
will not be remedied by the parent.

...

(b) Other considerations.--The court in terminating the rights
of a parent shall give primary consideration to the developmental,
physical and emotional needs and welfare of the child. The rights
of a parent shall not be terminated solely on the basis of
environmental factors such as inadequate housing, furnishings,
income, clothing and medical care if found to be beyond the
control of the parent. With respect to any petition filed pursuant
to subsection (a)(1), (6) or (8), the court shall not consider any
efforts by the parent to remedy the conditions described therein
which are first initiated subsequent to the giving of notice of the
filing of the petition.


3 Given our disposition relative to Section 2511(a)(2), we need not review and

make no conclusions as to the orphans’ court’s findings with respect to Section
2511(a)(8). See K.R., 200 A.3d at 979 (observing this Court may review one
subsection of Section 2511(a) “[w]ithout considering the orphans’ court’s
determinations” under any other subsection).

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J-S01019-26

23 Pa.C.S.A. § 2511(a)(2), (b).

To prove the applicability of Section 2511(a)(2), the party petitioning

for termination must establish: “(1) repeated and continued incapacity, abuse,

neglect or refusal; (2) that such incapacity, abuse, neglect or refusal caused

the child to be without essential parental care, control or subsistence; and (3)

that the causes of the incapacity, abuse, neglect or refusal cannot or will not

be remedied.” In re Adoption of A.H., 247 A.3d 439, 443 (Pa. Super. 2021)

(citation omitted). Grounds for termination pursuant to Section 2511(a)(2),

however, “are not limited to affirmative misconduct, but concern parental

incapacity that cannot be remedied.” Id. (citation omitted). We have long

recognized that “[p]arents are required to make diligent efforts towards the

reasonably prompt assumption of full parental duties.” Id. (citation omitted).

In this case, Mother argues that the court abused its discretion in

terminating her parental rights pursuant to Section 2511(a)(2) based on

insufficiency of the evidence. See Mother’s Brief at 21. Specifically, Mother

asserts that she has participated in drug and alcohol and mental health

treatment, as well as parenting classes. See id. at 21-23. Mother contends

that her participation in these programs, specifically parenting, has been

“positive,” and demonstrates her ability to provide “essential parental care” to

the Children. Id. at 23. We are constrained to disagree.

Here, the orphans’ court determined that Mother made minimal

progress in her parental skills during the three years of the Children’s

  • 10 - J-S01019-26

dependencies. See N.T., 8/8/25, at 8-9. Mother did not acknowledge her

parental deficits. See id. at 9-10, 12-14. In addition, the court found that

Mother’s drug and mental health issues and ongoing criminal activity

warranted termination under Section 2511(a)(2). See id. at 14-18. In

reviewing the evidence of record, we discern no abuse of discretion.

Dr. Bernstein conducted an interactional evaluation of L.G. and his foster

care resource in May 2025, an individual evaluation of Mother in July 2025,

and separate interactional evaluations of Mother and the Children in July 2025.

See Agency Exhibit 7; N.T., 8/8/25, at 12. Significantly, he had previously

conducted two joint interactional evaluations of Mother and the Children in

March 2023 and October 2024, which he concluded early due to Mother’s

failure to garner the Children’s compliance and cooperation and due to safety

concerns. See Agency Exhibit 7 at 2; N.T., 8/8/25, at 32-33, 39, 41-43.

Specifically, Dr. Bernstein explained that, during these two appointments,

Mother demonstrated

a marked inability to effectively support their needs, such as two
appointments she had been excused for not having capacity to
effectively support them and control them, one in which she had
been repeatedly assaulted and could not thwart that behavior by
her son, and in another instance the [C]hildren, she could not
enlist their cooperation[.] . . .

N.T., 8/8/25, at 15; see also id. at 39, 42, 105, 109. He testified that Mother

“has notably and consistently struggled in enforcing expectations, establishing

rules, providing structure, and eliciting [a] level of compliance” from the

  • 11 - J-S01019-26

Children. Id. at 34. Dr. Bernstein therefore recommended that Mother

participate in coached parenting.4 See id. at 34.

Although Mother completed a parenting program in January 2023, Ms.

Frank testified that Mother’s lack of progress required her to attend an

additional parenting program, which she failed to do, as well as coached

visitation, in which she participated from May 2023, through November 2024,

but did not successfully complete. See id. at 58-59. Ms. Frank recounted

several instances during Mother’s coached visitations where she failed to

appropriately supervise the Children near the street or parking lot; where

Mother appeared to be under the influence or suffering a mental health

episode; and where Mother attempted to abscond with the Children, which

resulted in Mother’s supervised visits being suspended for three months. See

id. at 64-69, 98-99, 102-03, 112-13. Furthermore, Ms. Frank testified that

coached visitation ultimately ended as the provider “felt they could not

maintain the [C]hildren’s behaviors in a safe manner . . . .” Id. at 105. As

such, as recently as June 2025, Ms. Frank expressed an intent to again refer

Mother for coached visitation. See id. at 118.

Significantly, Ms. Frank testified that Mother denied needing parenting

assistance. See id. at 70; see also id. at 92-93. Ms. Frank stated that

Mother “doesn’t accept [] advice” and “provides excuses” for the Children’s


4 We refer to coached parenting and coached visitation interchangeably.

  • 12 - J-S01019-26

behaviors and her inability to manage them. Id. at 89. She continued, “Even

when [Mother has] been prompted not only [by] myself, but the visit coach

who has more knowledge than myself about parenting, [Mother] would often

say that the visit coach is not qualified” to help her because the coach does

not “have children, not for any other reason. . . .” Id. at 70. Reflective of

this disavowal, Mother testified as follows when questioned by the court:

Q. Speaking of parenting, you did a coached parenting program,
is that correct?

A. Yeah, . . . yes, I did all of that.

Q. You did coached parenting prior to being incarcerated, right?

A. Yes.

Q. Did you find the coached parenting helpful?

A. I don’t think it’s that I’m a bad parent. I think every parent
could take like advice, you know, but the situation is because of
my sister calling and my mother had a gun in my house and they
took my children because there was a gun in my house, and my
sister lied and said I was on drugs and mentally unstable, so that’s
why my children were removed. Coach therapy -- I think I’m a
very good parent. . . .

Id. at 128 (cleaned up).

Additionally, as indicated, Mother was diagnosed with an adjustment

disorder, as well as cannabis abuse. See id. at 13. Ms. Frank acknowledged

Mother’s engagement in and compliance with drug and alcohol and mental

health treatment at times during the Children’s dependency proceedings. See

id. at 59-62, 83-84. However, Ms. Frank recounted that CYF did not have

documentation of any drug and alcohol and mental health treatment from

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Mother’s incarceration in December 2024 until her reengagement just a week

prior to the subject hearing. See id. at 62. While Mother indicated that she

participated in a program while incarcerated, Ms. Frank had no corroborating

information. See id. at 84-85, 125, 127. Moreover, Mother failed to report

consistently for drug and alcohol screening. In fact, she tested five times in

the year preceding the termination hearing, and four of those times the results

were positive for marijuana, most recently in May 2025. See Agency Exhibit

  1. Indeed, Dr. Bernstein testified that Mother reported marijuana use on a

“weekly basis.” See N.T., 8/8/25, at 13. Notwithstanding, Ms. Frank testified

that Mother does not believe she has a drug or mental health problem, and,

therefore, she does not accept any help. See id. at 90-93. Mother testified

that she merely “smokes because she misses [her] kids.” Id. at 123, 126-

27; see also id. at 13, 36-37, 58, 81. Importantly, Dr. Bernstein testified

that Mother’s diagnoses “did not compromise in and [of] itself her ability to

care for a child,” yet he admitted that Mother was “healthier and better

functioning” while in drug and alcohol and mental health treatment. Id. at

14.

Finally, as noted supra, Mother had an extensive criminal history,

including pending charges with an outstanding bench warrant. See id. at 57-

58; Agency Exhibit 4. She further acknowledged residing with her boyfriend

in housing that was not appropriate for the Children at the time of the subject

hearing. See N.T., 8/8/25, at 123; see also id. at 13, 36-37, 58, 81.

  • 14 - J-S01019-26

Accordingly, Ms. Frank testified that Mother was not able to care for the

Children on a full-time basis. See id. at 78. She explained:

My concern is that she has not made any progress in the three
years that she’s been involved with the [A]gency despite having
several referrals to several different services to address the
concerns in her court ordered goals and alleviate the need for the
[C]hildren to be placed. She has not shown that she has
maintained sobriety, that she’s adequately addressed her mental
health, that she has appropriate housing for the [C]hildren, or can
parent the [C]hildren effectively and safely, and there’s currently
pending criminal charges with an active warrant.

Id. at 78.

Based on the foregoing, we discern no abuse of discretion by the

orphans’ court in concluding that termination pursuant to Section 2511(a)(2)

is warranted. The record demonstrates that Mother’s repeated and continued

incapacities, including her drug and alcohol addiction, mental health issues,

and continuing criminal activity, have caused the Children to be without

essential parental care, control, or subsistence necessary for their physical or

mental well-being. Further, the record supports that the conditions and

causes of Mother’s incapacities cannot or will not be remedied given the

Children’s placement for more than three years, and Mother’s failure to

acknowledge her continued incapacities. See A.H., 247 A.3d at 443.

Since the record supports the orphans’ court’s conclusion that adequate

grounds for termination existed pursuant to at least one subsection of Section

2511(a), we now turn to a review of the court’s findings pursuant to Section

2511(b), which gives “primary consideration to the developmental, physical

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and emotional needs and welfare of the child.” 23 Pa.C.S.A. § 2511(b); see

also T.S.M., 71 A.3d at 267. Our Supreme Court has generally outlined this

inquiry, as follows:

[C]ourts should consider the matter from the child’s perspective,
placing her developmental, physical, and emotional needs and
welfare above concerns for the parent.

Accordingly, the determination of the child’s particular
developmental, physical, and emotional needs and welfare must
be made on a case-by-case basis. We have observed the law
regarding termination of parental rights should not be applied
mechanically but instead always with an eye to the best interests
and the needs and welfare of the particular children involved.
Thus, the court must determine each child’s specific needs.

Moreover, the child’s emotional needs and welfare include
intangibles such as love, comfort, security, and stability. As
further guidance, we have identified factors, i.e., specific needs
and aspects of the child’s welfare, that trial courts must always
consider. The courts must consider whether the children are in a
pre-adoptive home and whether they have a bond with their foster
parents. And, if the child has any bond with the biological parent,
the court must conduct an analysis of that bond, which is not
always an easy task.

Interest of K.T., 296 A.3d 1085, 1105-06 (Pa. 2023) (cleaned up).

“The extent of any bond analysis . . . necessarily depends on the

circumstances of the particular case.” In re K.Z.S., 946 A.2d 753, 762-63

(Pa. Super. 2008) (citation omitted). However, our Supreme Court has

concluded that “only a necessary and beneficial” parental bond should be

maintained. K.T., 296 A.3d at 1009. A bond is considered to be “necessary

and beneficial” if its severance would cause “extreme emotional

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consequences” or significant, irreparable harm. Id. at 1109-10. This Court

has recognized that,

concluding a child has a beneficial bond with a parent simply
because the child harbors affection for the parent is not only
dangerous, it is logically unsound. If a child’s feelings were
the dispositive factor in the bonding analysis, the analysis
would be reduced to an exercise in semantics as it is the
rare child who, after being subject to neglect and abuse, is
able to sift through the emotional wreckage and completely
disavow a parent. . . . Nor are we of the opinion that the
biological connection between [the parent] and the children
is sufficient in of itself, or when considered in connection
with a child’s feeling toward a parent, to establish a de facto
beneficial bond exists. The psychological aspect of
parenthood is more important in terms of the development
of the child and its mental and emotional health than the
coincidence of biological or natural parenthood.

In re K.K.R.-S., 958 A.2d 529, 535 (Pa. Super. 2008) (internal citations and

quotation marks omitted).

Furthermore, “bond, plus permanency, stability and all ‘intangible’

factors may contribute equally to the determination of a child’s specific

developmental, physical, and emotional needs and welfare, and thus are all of

‘primary’ importance in the Section 2511(b) analysis.” K.T., 296 A.3d at

  1. Therefore, it is “within the discretion of the orphans’ court to prioritize

the safety and security” of children “over their bonds with their parents.”

M.E., 283 A.3d at 839 (cleaned up).

Here, Mother first argues that the court erred by considering Section

2511(b) inasmuch as she claims that the Agency failed to meet its evidentiary

burden under Section 2511(a). See Mother’s Brief at 25. Because we have

  • 17 - J-S01019-26

already concluded that the court did not abuse its discretion with respect to

Section 2511(a)(2), Mother’s argument fails. In addition, Mother argues that

the court abused its discretion because a bond exists between her and the

Children, and neither of them are in a pre-adoptive placement. See id. at 25-

  1. Mother relies upon the testimony of Dr. Bernstein that a bond existed,

the severance of which would negatively impact the Children. See id. at 25.

For the reasons that follow, Mother is not entitled to relief.

In determining that termination of Mother’s parental rights served the

Children’s developmental, physical, and emotional needs and welfare pursuant

to Section 2511(b), the orphans’ court emphasized the Children’s need for

permanency. See N.T., 8/12/25, at 18-19, 24-25. While recognizing that the

Children shared a bond with Mother, the court relied on the testimony of Dr.

Bernstein that any negative impact by terminating Mother’s parental rights is

outweighed by the Children’s need for permanency. See id. at 21-22. Also

important to the court was Dr. Bernstein’s opinion that termination would not

result in “extreme” negative impact or interfere with the Children’s

development. Id. at 22. Dr. Bernstein elaborated on the reasons he found

that termination is not outweigh by the bond between Mother and the

Children. Upon review, we discern no abuse of discretion.

Dr. Bernstein testified that the bond that exists between the Children

and Mother has been diminished “by periods of absence related to [Mother’s]

legal difficulties and/or other circumstances in which she has either been

  • 18 - J-S01019-26

compromised in attending full visits or received increased scrutiny as to her

judgment and/or behavior[.]” See N.T., 8/8/25, at 20. As such, he opined

that the Children’s bond with Mother is not strong. See id. at 37-38. It

follows that Dr. Bernstein declined to classify any negative consequences to

the Children as extreme should Mother’s parental rights be terminated. See

id. at 46-47. Upon inquiry by the court, he testified, as follows:

THE COURT: . . . Finally, you have spoken about the potential
impact on the Children of termination of their mother’s rights, and
you spoke about how you would predict that they would
experience a negative impact of that, which I understand. The
appellate courts have talked about this question at times,
frequently actually, as asking whether a child would suffer
extreme emotional consequences if their parents’ rights were
terminated, and I wondered if you could give me any insight into
how negative the impact on them would be?

...

DR. BERNSTEIN: . . . I would not characterize the potential
effect upon the children as extreme, rather, that there would
be an impact and that they would feel the absence of their mother,
but . . . it would not rise to the level of however they would define
extreme that I would -- I would not view it as an extreme.

Id. at 46-47 (emphasis added). He further opined that the Children would

not suffer irreparable harm:

Q. Dr. Bernstein, is it the case that if you are able to tell at all,
ceasing contact with Mother would cause such pain as to cause
the Children difficulty in their emotional or psychological
development?

A. Ultimately of course no one is in a position to know with any
sense of certainty, but based upon everything that I have
reviewed and observed, no, it is not my determination that the
Children would be irreparably damaged, emotionally,
physically, psychologically harmed in such a way that they

  • 19 - J-S01019-26

could not otherwise function with the benefit of receiving a
supportive home environment, as well as any support services
that can be provided to help them through this transition, if that
was the court’s decision.

Id. at 48 (emphasis added). Dr. Bernstein agreed that the Children’s need

for permanency would outweigh any negative impact that terminating

Mother’s parental rights would have on them. See id. at 21-22.

Likewise, Ms. Frank expressed the Agency’s support for termination of

Mother’s parental rights due to the Children’s need for permanency. See id.

at 79. She testified that “termination will allow the [C]hildren to have a chance

of obtaining permanency and stability. Obviously[,] permanency is necessary

for children to have that stability, security, consistency, and have a better

potential of developing healthy, emotional, psychological and social

development.” Id.

In addition, Ms. Frank testified that Mother has at times, expressed her

disapproval of the recommended therapeutic treatment for the Children. See

id. at 78-79, 89. In contrast, the Children’s foster care parents ensure that

the Children receive all of the necessary services, and there has been

improvement in their behavior as a result. See id. at 73-74, 78-79, 88, 114-

16.

Thus, the record amply demonstrates that Mother and the Children do

not share a necessary and beneficial relationship. See K.T., 296 A.3d at

1109-10, 1113. While Mother may profess to love the Children, a parent’s

own feelings of love and affection for a child, alone, will not preclude

  • 20 - J-S01019-26

termination of parental rights. See In re Z.P., 994 A.2d 1108, 1121 (Pa.

Super. 2010) (citation omitted). Based upon our review of the record, we

discern no abuse of discretion in the court’s conclusion that the Children’s

developmental, physical, and emotional needs and welfare will be served by

the termination of Mother’s parental rights pursuant to Section 2511(b).5

Accordingly, we affirm the orders.

Orders affirmed.

3/17/2026


5 As stated above, Frank McWilson, Esquire, represented the Children’s legal

interests during the proceeding, and advocated for the court to deny the
involuntary termination petitions. However, since Attorney McWilson did not
file a brief in this appeal, we do not have the benefit of his position or
reasoning following the filing of the orders dated August 12, 2025, and entered
on August 27, 2025, by the orphans’ court involuntarily terminating Mother’s
parental rights to the Children.

  • 21 -

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
PA Superior Court
Filed
March 17th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Healthcare providers
Geographic scope
State (Pennsylvania)

Taxonomy

Primary area
Healthcare
Operational domain
Legal
Topics
Family Law Child Welfare

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