Termination of Parental Rights Statutory Provisions

TERMINATION OF PARENTAL RIGHTS

15-7 STATUTORY REQUISITES/PROVISIONS

The father sought review of the trial court order that terminated his parental rights to his son pursuant to the Adoption Act, 23 Pa.C.S. § 2511(a)(8) and (b). The trial court found that the child had been removed from his father for a two-year period, far beyond the one-year statutory requirement of 23 Pa.C.S. § 2511(a)(8). The court also found that the father’s periods of supervised visitation of approximately two hours per month were insufficient to foster a meaningful and healthy parental connection and that no bond existed between the child and the father. In general, the party seeking termination must prove by clear and convincing evidence that the parent’s lack of contact with his or her child satisfies at least one of the nine statutory grounds for termination of the parent’s parental rights listed in section 2511(a). If the trial court determines that the parent’s conduct warrants termination under section 2511(a), it must then engage in an analysis of the best interests of the child under section 2511(b), taking into primary consideration the developmental, physical, and emotional needs of the child. The appellate court may uphold a termination decision if any proper basis exists for the results reached. In re B.C., 36 A.3d 601 (Pa.Super. 2012).