Termination of Parental Rights • Housing Issues • Time in Foster Care • Attorney for Child

In the Interest of J.I.P., PICS Case No.17-1258 (Pa. Super. July 20, 2017) Shogan, J. (17 pages).

Trial court properly terminated mother's parental rights under §§2511(a) and (b) because the trial court's conclusions regarding mother's mental health and housing issues were supported by the record and she did not raise before the trial court any concerns that would have created the need for independent legal counsel for child nor did she make any claims that the attorney failed to properly represent the child's legal and best interests. Affirmed.

Department of human services became involved with mother in 2010 due to her drug use and inadequate housing and she was provided with in-home services and help getting substance abuse treatment. The housing and substance abuse issues continued, child was adjudicated dependent in 2012 and placed in a foster home with mother having supervised visitation. Department filed for involuntary termination of mother's parental rights and goal change to adoption in 2016. At the hearing, the trial judge admitted, by agreement of the parties, the notes of testimony from a 2015 termination/goal change hearing for three of child's siblings. Mother testified at the hearing. The trial court found that mother had failed to remedy the issues that brought child into care, that mother had not resolved her housing issues, that child had been in foster care for five years, that child had parental bond with the caretaker father who would be the adoption resource and terminated mother's parental rights. Mother appealed.