Adoption of: R.J.-K.G.-G., Appeal of: A.C.G.

CourtSuperior Court of Pennsylvania
DecidedJanuary 23, 2026
Docket1024 WDA 2025
StatusUnpublished
AuthorKing

This text of Adoption of: R.J.-K.G.-G., Appeal of: A.C.G. (Adoption of: R.J.-K.G.-G., Appeal of: A.C.G.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adoption of: R.J.-K.G.-G., Appeal of: A.C.G., (Pa. Ct. App. 2026).

Opinion

J-S46032-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

IN THE MATTER OF THE ADOPTION : IN THE SUPERIOR COURT OF OF: R.J.-K.G.-G., A MINOR : PENNSYLVANIA : : APPEAL OF: A.C.G., MOTHER : : : : : No. 1024 WDA 2025

Appeal from the Decree Entered July 22, 2025 In the Court of Common Pleas of Erie County Orphans' Court at No(s): 2025-A0055

BEFORE: BOWES, J., NICHOLS, J., and KING, J.

MEMORANDUM BY KING, J.: FILED: January 23, 2026

Appellant, A.C.G. (“Mother”), appeals from the decree entered in the

Erie County Court of Common Pleas, granting the petition of Appellee, the Erie

County Office of Children and Youth (“OCY”), for involuntary termination of

Mother’s parental rights to her minor child, R.J.-K.G.-G. (“Child”). We affirm.

The trial court opinion set forth relevant facts of this appeal as follows:

Child was born [in October] 2024. Child was removed by verbal request of OCY and subsequent Order for Verbal Authorization (Emergency Protective Custody) on October 11, 2024. Mother tested positive for benzodiazepines on a drug urine screen at the Child’s birth, and additionally had been admitted to Saint Vincent Hospital for an overdose and tested positive for benzodiazepines, cocaine, and opiates and refused referrals for services on August 22, 2024. Mother further was uncooperative in providing the agency her prescriptions and home address on October 10, 2024, preventing the agency from assuring the safety of the home. On October 10, 2024, the agency received a referral for Mother regarding concerns for parental behavior, health concerns, inadequate housing, and substance use by a J-S46032-25

parent. Child was adjudicated dependent on October 24, 2024. Mother’s Proposed Treatment Plan was as follows:

1. Submit to genetic testing to assist in establishing paternity.

2. Complete a mental health assessment and follow any and all recommendations made. Additionally, Mother shall demonstrate mental health stability.

3. Complete a drug and alcohol assessment through Erie County Drug and Alcohol and follow any and all recommendations made. Additionally, Mother shall be open and honest in her assessment and demonstrate skills learned.

4. Refrain from the use of drugs and/or alcohol and submit to random drug and alcohol testing through an agency approved location.

5. Maintain safe and stable housing with proof of residency. Additionally, Mother shall maintain working utilities and appropriate living conditions.

6. Participate in an agency approved parenting program and demonstrate skills learned.

7. Meet with the agency caseworker and sign all pertinent releases of information requested.

(Trial Court Opinion, filed 9/11/25, at 1-2) (internal record citations and

quotation marks omitted). Upon his removal from Mother’s care, OCY placed

Child with his maternal aunt. Child has remained in this placement ever since.

At the subsequent permanency review hearings, OCY established that

Mother had made minimal progress towards compliance with her treatment

plan. On May 22, 2025, OCY filed a petition for the involuntary termination

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of Mother’s parental rights to Child.1 The court conducted a termination

hearing on July 18, 2025. At that time, the court received testimony from an

OCY supervisor, the OCY caseworker, and an expert in clinical psychology.

Mother also testified on her own behalf. On July 22, 2025, the court entered

a decree terminating Mother’s parental rights to Child, pursuant to 23

Pa.C.S.A. § 2511(a)(1), (2), (5), and (b). Mother timely filed a notice of

appeal and concise statement of errors on August 12, 2025.

Mother now raises four issues for this Court’s review:

Whether the trial court erred in finding, under [Section] 2511(a)(1), that Mother evidenced a settled purpose to relinquish parental claim or failed to perform parental duties.

Whether the trial court erred under [Section] 2511(a)(2) by determining that any incapacity could not or would not be remedied.

Whether the court erred under [Section] 2511(a)(5) in concluding that the conditions leading to removal continued to exist despite Mother’s partial compliance and progress.

Whether the court erred under [Section] 2511(b) in finding termination was in the child’s best interests without adequately considering the parent-child bond or potential detriment.

(Mother’s Brief at 7).

Appellate review in termination of parental rights cases implicates the

____________________________________________

1 The petition also sought to terminate the parental rights of J.D.G. (“Father”).

By decree filed on July 18, 2025, the court terminated Father’s parental rights. Father is not a party to the current appeal.

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following principles:

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. This standard of review corresponds to the standard employed in dependency cases, and requires appellate courts to accept the findings of fact and credibility determinations of the trial court if they are supported by the record, but it does not require the appellate court to accept the [trial] court’s inferences or conclusions of law. That is, if the factual findings are supported, we must determine whether the trial court made an error of law or abused its discretion. An abuse of discretion does not result merely because the reviewing court might have reached a different conclusion; we reverse for an abuse of discretion only upon demonstration of manifest unreasonableness, partiality, prejudice, bias, or ill will. Thus, absent an abuse of discretion, an error of law, or insufficient evidentiary support for the trial court’s decision, the decree must stand. We have previously emphasized our deference to trial courts that often have first-hand observations of the parties spanning multiple hearings. However, we must employ a broad, comprehensive review of the record in order to determine whether the trial court’s decision is supported by competent evidence.

In re Adoption of C.M., 667 Pa. 268, 294-95, 255 A.3d 343, 358-59 (2021)

(internal citations and quotation marks omitted).

OCY filed a petition for the involuntary termination of Mother’s parental

rights on the following grounds:

§ 2511. Grounds for involuntary termination

(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:

* * *

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(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.

23 Pa.C.S.A. § 2511(a)(2), (b). “Parental rights may be involuntarily

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Related

In re C.P.
901 A.2d 516 (Superior Court of Pennsylvania, 2006)
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923 A.2d 505 (Superior Court of Pennsylvania, 2007)
In re Involuntary Termination of Parental Rights to E.A.P.
944 A.2d 79 (Superior Court of Pennsylvania, 2008)
In re Z.P.
994 A.2d 1108 (Superior Court of Pennsylvania, 2010)
In Re: C.P.D., Appeal of: T.P.D.
2024 Pa. Super. 201 (Superior Court of Pennsylvania, 2024)

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Adoption of: R.J.-K.G.-G., Appeal of: A.C.G., Counsel Stack Legal Research, https://law.counselstack.com/opinion/adoption-of-rj-kg-g-appeal-of-acg-pasuperct-2026.