In Re: P.A.M., a Minor

Superior Court of Pennsylvania·Decided May 11, 2026·No. 60 MDA 2026·Unpublished·Beck

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

IN RE: P.A.M., A MINOR : IN THE SUPERIOR COURT OF : PENNSYLVANIA :

APPEAL OF: A.S., MOTHER :

: : : : No. 60 MDA 2026 :

Appeal from the Order Entered November 21, 2025 In the Court of Common Pleas of Berks County Orphans' Court at No(s):

89019

BEFORE: BECK, J., NEUMAN, J., and BENDER, P.J.E.

MEMORANDUM BY BECK, J.: FILED: MAY 11, 2026

A.S. (“Mother”) appeals from the order entered by the Berks County

Court of Common Pleas (“orphans’ court”) granting the petition filed by B.M.

(“Father”) and terminating her parental rights to P.A.M., born in October 2015

(“Child”), pursuant to 23 Pa.C.S. § 2511(a)(1), (2), (9)(ii), and (b). Counsel

for Mother, Attorney Emily E.B. Cherniack (“Counsel”), has filed a petition to

withdraw and brief pursuant to Anders v. California, 386 U.S. 738 (1967),

and Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009).1 After review,

1 See Interest of R.S.A.D., 341 A.3d 787, 794 (Pa. Super. 2025) (recognizing that the Anders/Santiago procedure for court-appointed counsel seeking to withdraw has been extended to appeals involving termination of parental rights).

we grant Counsel’s petition to withdraw and affirm the orphans’ court’s

decision.2

The orphans’ court aptly summarized the facts and circumstances

underlying this appeal:

Child was born to Mother and Father in 2015. Mother and Father resided together for approximately one and a half years after Child was born. ln 2017, Father ended the relationship with Mother, who at the time retained primary custody, with Father visiting daily. A temporary custody order in 2019 shifted primary custody to Father, followed by a final custody order reaffirming Father’s primary custody in 2021. Father has exercised exclusive physical and legal custody of Child since May 2021.

Child is the only offspring of Mother and Father. Mother had three other children (two older than child and one younger)[; she retains her parental rights only as to the two older children].

2 Child was represented by a single attorney at the termination hearing, Attorney Mark Zimmer, who represented both her legal interests as counsel and her best interests as her guardian ad litem (“GAL”). Orphans’ Court Order, 11/21/2024. The orphans’ court found there was no conflict between Child’s best and legal interests and that Attorney Zimmer could therefore fulfill both roles. See N.T., 10/2/2025, at 3; see also Orphans’ Court Opinion, 1/30/2026, at 9 (“The orphans’ court on multiple occasions, both before (at multiple pretrial conferences) and during the termination hearing, inquired as to the investigation performed by Attorney Zimmer, Child’s wishes, and whether those wishes conflicted with Attorney Zimmer’s recommendation applying a best interest duty analysis.”) (cleaned up). We remind the orphans’ court, however, that its conflict determination in this regard should appear in its order of appointment. See In re Adoption of K.M.G., 240 A.3d 1218, 1236 (Pa. 2020) (stating that appellate courts must conduct a sua sponte review to discern “(1) whether the orphans’ court appointed counsel to represent the legal interests of the children and (2) if the appointed counsel also serves as GAL, whether the orphans’ court determined that the child’s best interests and legal interests did not conflict,” observing that this can be accomplished “by a review of the orphans’ court order (or lack thereof) appointing counsel to represent a child under Section 2313(a)”).

Father, who is now married, has a stepson from that relationship, but no other biological children; Mother remains single.

The custodial shift from Mother to Father in 2019 was contemporaneous with Mother’s arrest on charges related to the alleged neglect of her youngest child (an infant at the time)— Child’s half-sibling. On March 9, 2022, Mother pleaded to a single count of aggravated assault [pursuant to 18 Pa.C.S. § 2702(a)(9)]. On April 18, 2022, the [criminal court] sentenced Mother in an open plea to [thirty] months to seven years in a state correctional institution. [Her sentence prohibited her from having any contact with the victim or unsupervised contact with any child under eighteen.] In April 2025, Mother was paroled to a transitional halfway house.

The controlling final custody order of January 6, 2021 (predating Mother’s incarceration) permits Mother only supervised visitation with Child. Although Mother initially participated in supervised visits, she did not participate in visits with Child for approximately one year prior to her incarceration.

1. Father’s Testimony

Father appeared to be in good health and sound mind when appearing before the orphans’ court and testifying. The orphans’ court found him to be thoughtful in his answers and credible in whole.

Father recounted the time from when Child was born until the present. He detailed that he met his now wife a few months after breaking up with Mother. Father lives with his wife, her son, and Child. Father testified that Child has a great relationship with her stepmother, and that “they love each other.” N.T., 10/2/2025, at 16. Stepmother has expressed that she wishes to adopt Child. Father told the court that his stepson—an eighteenyear -old high school senior—also has a great relationship with Child. Id. Father describes the relationship between stepson and Child as a brother-sister bond, indicating that the stepson is protective of Child, helps her with homework, and that the two often joke around with one another. Id.

Father testified that Mother’s visitations with Child following the final custody order were to either be supervised by Child’s maternal grandfather or Signature Family Services (“Signature”)[, an organization with offices in several counties that provides, inter

alia, supervision in child custody and dependency matters]. He said Mother took advantage of these visits on an average of once per week but that all visits stopped by May [2021]. Id. at 7. Father explained that maternal grandfather no longer wanted to act as a supervisor for visits after recurring conflict with Mother. Father said Mother was also unable to get along with representatives from Signature, whose Berks County office sought to potentially transfer the case to Signature’s Schuylkill County location[—approximately thirty-five miles away—]due to difficulty with Mother. Id. at 8. Father did not agree with the timing of the request, nor did he think moving the location of the supervised visits would be conducive to Child’s best interests with keeping in a routine.

… Father said after Mother was incarcerated in April 2022, she sent Child between eight and ten letters from prison. Id. at 14. Father said he gave them to Child and that he would read them to her if she was unable to read any parts of the letters. Child instructed him to throw the letters away. Id. Father testified further that he kept some of the letters for child because “he wanted her to have something.” When asked if Mother sent child any gifts during this time, Father said the only item that might be a gift was a hand drawn picture sent from Mother. Id. at 15. Father testified that he has never received any sort of child support from Mother. Id.

Father believes it would be in Child’s best interests for Mother’s parental rights to be terminated because Mother has not had any contact with Child, and that Child does not want to have any contact with Mother. He also worries for Child’s safety in consideration of what Mother has done with her other children. Id. at 17. Father also stated Child became scared and depressed upon learning Mother had been released from prison. Id. at 21. Child has asked Father to be kept away from Mother and to never have to speak to her again. Id.

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