In Re: S.H.A., Appeal of: K.L.A.

CourtSuperior Court of Pennsylvania
DecidedFebruary 11, 2026
Docket1942 EDA 2025
StatusUnpublished
AuthorKunselman

This text of In Re: S.H.A., Appeal of: K.L.A. (In Re: S.H.A., Appeal of: K.L.A.) 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
In Re: S.H.A., Appeal of: K.L.A., (Pa. Ct. App. 2026).

Opinion

J-S43014-25 J-S43015-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

IN RE: S.H.A., A MINOR : IN THE SUPERIOR COURT OF : PENNSYLVANIA : APPEAL OF: K.L.A., MOTHER : : : : : : No. 1942 EDA 2025

Appeal from the Decree Entered July 8, 2025 In the Court of Common Pleas of Lehigh County Orphans' Court at No(s): A2025-0007

IN RE: S.H.A., A MINOR : IN THE SUPERIOR COURT OF : PENNSYLVANIA : APPEAL OF: A.T.A., FATHER : : : : : : No. 1997 EDA 2025

Appeal from the Decree Entered July 8, 2025 In the Court of Common Pleas of Lehigh County Orphans' Court at No(s): A2025-0007

BEFORE: KUNSELMAN, J., McLAUGHLIN, J., and BENDER, P.J.E.

MEMORANDUM BY KUNSELMAN, J.: FILED FEBRUARY 11, 2026

In these matters, K.L.A. (Mother) and A.T.A. (Father) appeal from the

decrees that terminated their parental rights to their now over two-year-old

son, S.H.A. (the Child or Child), pursuant to the Adoption Act. See 23

Pa.C.S.A. § 2511(a)(1), (a)(2), (a)(5), (a)(8), and (b). Because each parent’s

appeal raises substantially the same issues and involves the same facts and J-S43014-25 J-S43015-25

circumstances, we address the parents’ appeals together in one decision.

After review, we affirm.

We discern the following factual and procedural history from the

orphans’ court’s opinion. In October 2023, while Mother was pregnant with

the Child, Mother and Father traveled from Lehigh County to Philadelphia to

buy illegal drugs. On the way, Mother went into labor and had an emergency

c-section in Philadelphia.

At his birth, the Child and Mother tested positive for several illicit

substances. Mother told medical staff she had been using two to three bags

of heroin daily, which was a reduction due to her concern that the drugs would

impact the Child. Mother was fearful that if she went through withdrawal while

pregnant, the Child would suffer. Within a few days after his birth, it became

obvious that the Child was drug-impacted. He was placed in the NICU. While

the Child was hospitalized, Mother and Father visited him only a handful of

times, with the last visit being on October 24, 2023. Conversely, a foster

family began visiting the Child daily. The Child was discharged into the foster

family’s care in November 2023, five and a half weeks after he was born, and

he has remained there ever since.

The Child was adjudicated dependent. Mother’s court-ordered

recommendations included: submitting urinalysis to show sobriety as

recommended by the Lehigh County Office of Children and Youth Services (the

Agency); completing a drug and alcohol evaluation and any treatment

recommended; and obtaining and maintaining legal income and stable

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housing. Father’s court-ordered recommendations included: submitting

urinalysis to show sobriety as recommended by the Agency; obtaining and

maintaining legal income and stable housing; and notifying the Agency of any

changes in his address or contact information.

Over the next fourteen months, Mother and Father failed to comply with

their court-ordered recommendations and did not maintain contact with the

Agency or the Child. On February 7, 2025, the Agency filed petitions to

involuntarily terminate Mother’s and Father’s parental rights. The orphans’

court held a termination hearing on April 23, 2025. 1 Two Agency caseworkers,

____________________________________________

1 The Child was represented by counsel at the termination hearing who also

served as the Child’s guardian ad litem (GAL) in the dependency proceedings.

Our Supreme Court has mandated that appellate courts sua sponte “verify that the orphans’ court indicated that the attorney [in a dual role of GAL and legal counsel] could represent the child’s best interests and legal interests without conflict.” In re Adoption of K.M.G., 240 A.3d 1218, 1236 (Pa. 2020); see also 23 Pa.C.S.A. § 2313(a). Counsel representing a child’s legal interests must advocate for the child’s preferred outcome even if counsel does not agree with it, whereas the GAL representing a child’s best interests must express what the GAL “believes is best for the child’s care, protection, safety, and wholesome physical and mental development regardless of whether the child agrees.” In re T.S., 192 A.3d 1080, 1082 n.2 (Pa. 2018) (citation omitted).

Here, the record does not contain clear findings by the trial court regarding whether a conflict existed between the Child’s legal and best interests. However, the Child was a little over a year and a half old at the time of the termination hearing, and there is record evidence that he was still learning to speak and had a limited vocabulary. See N.T., 4/23/25, at 68, 75, 77, 81; Recommendations – Permanency Review, 3/19/24, 9/12/24, 2/25/25 (noting that the Child was too young to express his views). Given the Child’s young age and his stage of development, it would have been impossible to ascertain (Footnote Continued Next Page)

-3- J-S43014-25 J-S43015-25

a foster care adoption case manager, and Mother testified. On July 8, 2025,

the orphans’ court involuntarily terminated Mother’s and Father’s parental

rights to the Child.

Mother and Father timely filed these appeals. We will address Mother’s

appeal first. Mother presents the following two issues 2 for our review: ____________________________________________

his preferred outcome. Thus, there could not have been a conflict between the Child’s interests, and dual representation was appropriate. See T.S., 192 A.3d at 1088 (recognizing that “where a child is too young to express a preference, it would be appropriate for the GAL to represent the child’s best and legal interests simultaneously.” (citation omitted)).

Nevertheless, we remind the orphans’ court and all counsel that the orphans’ court is required to determine whether counsel can represent the dual interests of a child before appointing an individual to serve as GAL/counsel for the child. See K.M.G., supra. The orphans’ court is not permitted to delegate this responsibility to counsel. See Matter of Adoption of A. C. M., 333 A.3d 704, 708-09 (Pa. Super. 2025). As a best practice, when a child is too young to express a preference, the orphans’ court should indicate this in the order appointing the GAL as the child’s legal counsel for the termination proceeding.

2 Mother’s Appellate Rule 1925(b) statement raises approximately six issues,

none of which directly match the issues she lists in her brief. See Mother’s Concise Statement of Matters Complained of on Appeal. Two of her issues broadly challenge the termination by stating that it was not supported by sufficient evidence and that the Agency had not met its burden of proof. See id. Although her next three issues do not specifically cite which statutory subsections she is challenging, we surmise from the language used that they refer to Section 2511(a)(2), (5), and (8). See id. Mother’s sixth issue cites Section 2511(a)(8) and (b). See id. However, none of Mother’s issues specifically cite Section 2511(a)(1) or use the language from that subsection. See id.

We remind and caution Mother and her counsel that, pursuant to Appellate Rule 1925(b), issues “not included in the Statement and/or not raised in accordance with the provisions of this paragraph (b)(4) are waived.” Pa.R.A.P. (Footnote Continued Next Page)

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1.

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In Re: S.H.A., Appeal of: K.L.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sha-appeal-of-kla-pasuperct-2026.