387 Pennsylvania opinions name it 5 courts 1868–2026 143 in the last five years
The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In re Adoption of S.P.green2 sentences2025See S.P., 47 A.3d at 828 . - 13 - J-S23014-25 Turning to Father’s issue with respect to Section 2511(b), he again bases it on the flawed premise that the CUA “prevent[ed] virtual visitation with his daughter.” Father’s Brief at 15 (unpaginated). 2020Father’s brief at 7 (extraneous capitalization omitted).9 In matters involving involuntary termination of parental rights, our standard of review is as follows: The standard of review in termination of parental rights cases requires appellate courts “to accept the findings of fact and credibility determinations of the trial court if they are supported by the record.” In re Adoption of S.P., 47 A.3d 817, 826 (Pa. 2012). | 18 | 21 |
In Re: Adopt of: A.H., Appeal of: C.W.green2 sentences2025To satisfy the requirements of Section 2511(a)(2), the petitioner must prove “(1) repeated and continued incapacity, abuse, neglect or refusal; (2) that such incapacity, abuse, neglect or refusal caused the child to be without essential parental care, control or subsistence; and (3) that the causes of the incapacity, abuse, neglect or refusal cannot or will not be remedied.” In re A.H., 247 A.3d 439, 443 (Pa. Super. 2021) (citation omitted). 2024Rather, Child shared a parent-child bond and beneficial relationship with her foster family, where she desires to remain. - 18 - J-S04029-24 Given our disposition concerning termination, Father’s challenge of the goal change order, reflected by his sixth issue, is moot.12 See Interest of A.M., 256 A.3d 1263, 1272-1273 (Pa. Super. 2021) (finding issues regarding goal change moot in light of termination of parental rights); A.H., 247 A.3d at 446 (“[T]he effect of our decision to affirm the orphans’ court’s termination decree necessarily renders moot the dependency court’s decision to change Chil | 11 | 11 |
In the Int. of: D.R.-W., a Minor Appeal of: D.W.green2 sentences2025See D.R.-W., 227 A.3d at 917 (stating that “[a]n issue before a court is moot if in ruling upon the issue the court cannot enter an order that has any legal force or effect” (citation omitted)); see also In re Adoption of A.H., 247 A.3d 439, 446 (Pa. Super. 2021) (stating that “the effect of our decision to affirm the orphans’ court’s termination decree necessarily renders moot the dependency court’s decision to change [a c]hild’s goal to adoption” (citation omitted)). 2024See In re Adoption of A.H., 247 A.3d 439, 446 (Pa. Super. 2021) (stating, “the effect of [this Court’s] decision to affirm the [trial] court's termination decree necessarily renders moot the [trial] court's decision to change [the permanent placement] goal to adoption”), appeal denied, 258 A.3d 1144 (Pa. 2021); see also Interest of A.R., ___ A.3d ___, 2023 WL 8226326 , at *7 (Pa. Super. 2023) (slip opinion) (stating, because “the trial court did not abuse its discretion in granting the petition to terminate [] parental rights, [a challenge to the change of the permanent placement goal] is moot | 8 | 8 |
In the Int of: D.C.D./ Appeal of: Clinton Co C&YSgreen2 sentences2025Although the record supports Father’s claim that, in early 2024, WCCB discontinued the transportation services it had previously offered Father, we have stated: “The agency is not required to offer services indefinitely, where a parent is unable to properly apply the instruction provided.” In re R.M.G., 997 A.2d 339, 347 (Pa. Super. 2010) (citation omitted); see also In re D.C.D., 105 A.3d 662, 672 (Pa. 2014) (stating that the Adoption Act does not “require[] a court to consider the reasonable efforts provided to a parent prior to termination of parental rights[,]” but noting that the ”absence 2018Father’s claim is misplaced based on our Supreme Court’s holding in D.C.D., supra at 672 , that neither Section 2511(a) nor (b) “requires a court to consider the reasonable efforts provided to a parent prior to termination of parental rights.” Therefore, Father’s claim fails. | 7 | 9 |
S.K.C. v. J.L.C.green2 sentences2020S.K.C. v. J.L.C., 94 A.3d 402, 406 (Pa. Super. 2014). 2018Relying on our decision in S.K.C. v. J.L.C., 94 A.3d 402 (Pa. Super. 2014), he asserts that, “there can be no hypothetical determination of inconvenient forum as it might exist at some point in the future.” Father’s brief at 24. | 7 | 8 |
McMillen v. McMillengreen2 sentences2004See McMillen v. McMillen, 529 Pa. 198 , 602 A.2d 845, 847 (1992) (child’s stated preference not controlling, but must be considered in determining child’s best interests; weight must be considered in light of maturity and intelligence and is best determined by the trial judge). ¶ 4 Contrary to Father’s claim, Mother did not abandon her role in the Child’s life because of the decision to enroll her in Girard College. 2004See McMillen v. McMillen, 529 Pa. 198 , 602 A.2d 845, 847 (1992) (child’s stated preference not controlling, but must be considered in determining child’s best interests; weight must be considered in light of maturity and intelligence and is best determined by the trial judge). ¶ 4 Contrary to Father’s claim, Mother did not abandon her role in the Child’s life because of the decision to enroll her in Girard College. | 7 | 7 |
In Re: M.Z.T.M.W., a minor, Appeal of: M.W.green2 sentences2026See Pa.R.A.P. 2116(a) (“No question will be considered unless it is stated in the statement of questions involved or is fairly suggested thereby.”); In re M.Z.T.M.W., 163 A.3d 462 , ____________________________________________ 1 Mother has filed an application to strike Father’s brief on this basis. -3- J-S08030-26 466 (Pa. Super. 2017) (It “is well-settled that issues not included in an appellant’s statement of questions involved and concise statement of errors complained of on appeal are waived.” (citation omitted)). 2022Likewise, the first three issues listed in Father’s statement of questions presented are waived because he failed to provide meaningful discussion with citation to any statutory authority or caselaw regarding (1) the guarantee of due process of law under the Fourteenth Amendment to the United States Constitution; (2) the admission of hearsay and limitation of cross-examination during the December 7, 2021 termination of parental rights hearing; or (3) the trial court’s alleged discrimination against him due to a physical disability - 12 - J-S17033-22 and inability to speak English.6 In re M.Z.T | 6 | 8 |
C.R.F. v. S.E.Fgreen2 sentences2021Rather, our standard of review requires that we “accept findings of the trial court that are supported by competent evidence of record, as our role does not include making independent factual determinations.” C.R.F., III v. S.E.F., 45 A.3d 441, 443 (Pa. Super. 2012). 2019See C.R.F. v. S.E.F., 45 A.3d 441, 443 (Pa. Super. 2012). | 6 | 8 |
Peters v. Costellogreen2 sentences2017As we recently reiterated in K.W., supra, at 504-505 , “The term in loco par-entis literally means ‘in the place of a parent.’ ” (quoting Peters v. Costello, 586 Pa. 102 , 891 A.2d 705, 710 (2005)). 2017As we recently reiterated in K.W., supra, at 504-505 , “The term in loco par-entis literally means ‘in the place of a parent.’ ” (quoting Peters v. Costello, 586 Pa. 102 , 891 A.2d 705, 710 (2005)). | 6 | 6 |
Collins v. Collinsgreen2 sentences2017See Collins, supra. Father’s error did not alter the nature of the custody litigation. 2017See Collins, supra. Father’s error did not alter the nature of the custody litigation. | 6 | 6 |
In Re WHgreen2 sentences2022See In re W.H., 25 A.3d 330 , 339 n.3 (Pa. Super. 2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa. Super. 2010)) (“[W]here an appellate brief fails to provide any (Footnote Continued Next Page) -7- J-S30016-22 Preliminarily, we observe that Father’s brief does not comport with the Pennsylvania Rules of Appellate Procedure, as argued by DHS. 2021See In re W.H., 25 A.3d 330 , 339 n.3 (Pa.Super. 2011), appeal denied, 611 Pa. 643 , 24 A.3d 364 (2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa.Super. 2010)) (“[W]here an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.”); see also In re M.Z.T.M.W., 163 A.3d 462, 465-66 (Pa.Super. 2017).13 ____________________________________________ 13 We note that, even if Father’s claim were preserved, it would be without merit. | 5 | 8 |
In Re B.,N.M.green2 sentences2019Father recognized that “parental duty requires that the parent act affirmatively with good faith interest and effort, and not yield to every problem, in order to maintain the parent-child relationship to the best of [his] ability, even in difficult circumstances.” Father’s brief at 19 (quoting In re B.,N.M., 856 A.2d at 855 ). 2019See In re K.Z.S., 946 A.2d at 763 (affirming involuntary termination of parental rights, despite existence of some bond, where placement with mother would be contrary to child’s best interests). “[A] parent’s basic constitutional right to the custody and rearing of his or her child is converted, upon the failure to fulfill his or her parental duties, to the child’s right to have proper parenting and fulfillment of [the child’s] potential in a permanent, healthy, safe environment.” In re B.,N.M., 856 A.2d at 856 (internal citations omitted). - 12 - J-S47038-19 In its Opinion, the trial court ad | 5 | 7 |
In Re CSgreen2 sentences2022We have defined clear and convincing evidence as that which is so “clear, direct, weighty and convincing as to enable the trier of fact to come to a clear conviction, without hesitance, of the truth of the precise facts in issue.” In re C.S., 761 A.2d 1197, 1201 (Pa.Super. 2000) (en banc) (cleaned up). 2022We have defined clear and convincing evidence as that which is so “clear, direct, weighty and convincing as to enable the trier of fact to come to a clear conviction, without hesitance, of the truth of the precise facts in issue.” In re C.S., 761 A.2d 1197, 1201 (Pa.Super. 2000) (en banc) (cleaned up). | 5 | 6 |
In the Interest of: A.M., a Minorgreen2 sentences2024Rather, Child shared a parent-child bond and beneficial relationship with her foster family, where she desires to remain. - 18 - J-S04029-24 Given our disposition concerning termination, Father’s challenge of the goal change order, reflected by his sixth issue, is moot.12 See Interest of A.M., 256 A.3d 1263, 1272-1273 (Pa. Super. 2021) (finding issues regarding goal change moot in light of termination of parental rights); A.H., 247 A.3d at 446 (“[T]he effect of our decision to affirm the orphans’ court’s termination decree necessarily renders moot the dependency court’s decision to change Chil 2022See Interest of A.M., 256 A.3d 1263 , - 20 - J-S33016-21 1272-73 (Pa. Super. 2021). | 5 | 5 |
Commonwealth v. Dunsongreen2 sentences2022See In re W.H., 25 A.3d 330 , 339 n.3 (Pa. Super. 2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa. Super. 2010)) (“[W]here an appellate brief fails to provide any (Footnote Continued Next Page) -7- J-S30016-22 Preliminarily, we observe that Father’s brief does not comport with the Pennsylvania Rules of Appellate Procedure, as argued by DHS. 2021See In re W.H., 25 A.3d 330 , 339 n.3 (Pa.Super. 2011), appeal denied, 611 Pa. 643 , 24 A.3d 364 (2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa.Super. 2010)) (“[W]here an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.”); see also In re M.Z.T.M.W., 163 A.3d 462, 465-66 (Pa.Super. 2017).13 ____________________________________________ 13 We note that, even if Father’s claim were preserved, it would be without merit. | 5 | 5 |
Gwin v. Merkingreen2 sentences2022In re N.C., supra; In re B.L.W., supra. Because we have concluded that the trial court did not abuse its discretion in granting the petition to terminate Father’s parental rights, Father’s challenge to the goal change is moot. 2008We need not consider the remaining subsections since “we need only agree with [the trial court’s] decision as to any one subsection in order to affirm the termination of parental rights.” In Re B.L.W., 843 A.2d 380, 384 (Pa.Super.2004) (en banc) (citations omitted), appeal denied, 581 Pa. 668 , 863 A.2d 1141 (2004). ¶ 8 The argument section of Father’s brief focuses on Section 2511(b), as he contends that the trial court failed to make the requisite inquiry into “the extent of the bond between him and the children and the effect a termination [sic] would have on the children.” Appellant’s brie | 4 | 6 |
S.T. v. R.W.green2 sentences2024Father’s claim of a procedural due process violation presents “a question of law for which the standard of review is de novo and the scope of review is plenary.” S.T. v. R.W., 192 A.3d 1155, 1160 (Pa. Super. 2018) (citation omitted); see also id. (“In custody hearings, parents have at stake fundamental rights: namely, the right to make decisions concerning the care, custody, and control of their child.”). - 23 - J-A11040-24 Instantly, a review of the evidence presented at the modification hearing is necessary. 2024Father’s claim of a procedural due process violation presents “a question of law for which the standard of review is de novo and the scope of review is plenary.” S.T. v. R.W., 192 A.3d 1155, 1160 (Pa. Super. 2018) (citation omitted); see also id. (“In custody hearings, parents have at stake fundamental rights: namely, the right to make decisions concerning the care, custody, and control of their child.”). - 23 - J-A11040-24 Instantly, a review of the evidence presented at the modification hearing is necessary. | 4 | 5 |
In Re Rmggreen2 sentences2025Although the record supports Father’s claim that, in early 2024, WCCB discontinued the transportation services it had previously offered Father, we have stated: “The agency is not required to offer services indefinitely, where a parent is unable to properly apply the instruction provided.” In re R.M.G., 997 A.2d 339, 347 (Pa. Super. 2010) (citation omitted); see also In re D.C.D., 105 A.3d 662, 672 (Pa. 2014) (stating that the Adoption Act does not “require[] a court to consider the reasonable efforts provided to a parent prior to termination of parental rights[,]” but noting that the ”absence 2022See R.M.G., 997 A.2d at 347 . | 4 | 4 |
In re T.S.M.green2 sentences2022In re T.S.M., 71 A.3d 251, 267 (Pa. 2013) (citations omitted and formatting altered). “[T]he trial court is free to believe all, part, or none of the evidence presented, and is likewise free to make all credibility determinations and ____________________________________________ 7 Father’s brief cites very little case law and instead relies heavily upon law review articles and the United Nations’ website, which are not precedential authorities. 2018We have previously emphasized our deference to trial courts that often have first-hand observations of the parties spanning multiple hearings. ____________________________________________ 2 While S.G.S.’s court-appointed counsel declined to file an independent brief, she joined the arguments raised in Father’s brief. -4- J-S85015-17 In re T.S.M., 71 A.3d 251, 267 (Pa. 2013) (citations and quotation marks omitted). | 4 | 4 |
In the Interest of K.Z.S.green2 sentences2019See In re K.Z.S., 946 A.2d at 763 (affirming involuntary termination of parental rights, despite existence of some bond, where placement with mother would be contrary to child’s best interests). “[A] parent’s basic constitutional right to the custody and rearing of his or her child is converted, upon the failure to fulfill his or her parental duties, to the child’s right to have proper parenting and fulfillment of [the child’s] potential in a permanent, healthy, safe environment.” In re B.,N.M., 856 A.2d at 856 (internal citations omitted). - 12 - J-S47038-19 In its Opinion, the trial court ad 2019See In re K.Z.S., 946 A.2d at 763 (affirming involuntary termination of parental rights, despite existence of some bond, where placement with mother would be contrary to child’s best interests). “[A] parent’s basic constitutional right to the custody and rearing of his or her child is converted, upon the failure to fulfill his or her parental duties, to the child’s right to have proper parenting and fulfillment of [the child’s] potential in a permanent, healthy, safe environment.” In re B.,N.M., 856 A.2d at 856 (internal citations omitted). - 12 - J-S47038-19 In its Opinion, the trial court ad | 3 | 6 |
Estate of Haiko v. McGinleygreen2 sentences2022See Pa.R.A.P. 2119(a) (stating that the argument shall include “discussion and citation of authorities as are deemed pertinent”); In re Adoption of A.P., 920 A.2d 1269, 1275 (Pa. Super. 2007) (concluding that the failure to properly develop or cite any legal authority in support of an argument results in waiver); Estate of Haiko v. McGinley, 799 A.2d 155, 161 (Pa. Super. 2002) (“Without a reasoned discussion of the law … our ability to provide appellate review is hampered. 2022See Estate of Haiko, supra. Regardless, we would conclude that Father’s claim regarding the trial court’s findings under section 2511(b) is meritless. | 3 | 4 |
In Re CLGgreen2 sentences2025“The standard of ‘clear and convincing’ evidence is defined as testimony that is so clear, direct, weighty, and convincing as to enable the trier of fact to come to a clear conviction, without hesitance, of the truth of the precise facts in issue.” In re Adoption of C.L.G., 956 A.2d 999, 1004 (Pa. Super. 2008) (en banc) (citation omitted). - 15 - J-A02022-25 Instantly, we examine Father’s challenge pursuant to Section 2511(a)(2),4 which provides: (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: *** (2) The 2016We will review Section 2511(b) pursuant to In re C.L.G., 956 A.2d 999, 1010 (Pa. Super. 2008) (en banc) (considering Section 2511(b) despite the appellant’s failure to challenge the court’s analysis).4 ____________________________________________ 4 In his statement of questions involved, Father indicates that he is challenging the findings of the orphans’ court that he “took little interest in the child and that it would be in the best interest of the child to have [Father’s] parental rights terminated[.]” Father’s brief at 2. | 3 | 3 |
| In Re IJgreen | 3 | 3 |
| Barrett, A. v. M&B Medical Billing, Inc.green | 3 | 3 |
| Calabrese v. Calabresegreen | 3 | 3 |
| Krebs v. United Refining Co. of Pennsylvaniagreen | 3 | 3 |
| In Re Adoption of R.J.S.green | 3 | 3 |
| Astorino v. New Jersey Transit Corp.green | 3 | 3 |
| C.B. v. J.B.green | 3 | 3 |
| Cramer v. Zgelagreen | 3 | 3 |
| Conroy v. Rosenwaldgreen | 3 | 3 |
| Kohler v. Bleemgreen | 3 | 3 |
In Re ZPgreen2 sentences2025Father’s claim fails insofar as “[S]ection 2511(b) does not require a formal bonding evaluation.” In re Z.P., 994 A.2d 1108, 1121 (Pa.Super. 2010) (citation omitted). 2023Although an involuntary termination decision also requires a trial court to consider the best interests of the child under subsection 2511(b) as a separate analysis from whether there is ground for involuntary termination, see In re Z.P., 994 A.2d at 1121 , neither Father’s statement of questions nor his argument section in Father’s brief makes any mention of that section. | 2 | 6 |
PETRINA v. Kelleygreen2 sentences2021See In re W.H., 25 A.3d 330 , 339 n.3 (Pa.Super. 2011), appeal denied, 611 Pa. 643 , 24 A.3d 364 (2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa.Super. 2010)) (“[W]here an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.”); see also In re M.Z.T.M.W., 163 A.3d 462, 465-66 (Pa.Super. 2017).13 ____________________________________________ 13 We note that, even if Father’s claim were preserved, it would be without merit. 2018See Krebs v. United Refining Co. of Pa., 893 A.2d 776, 797 (Pa. Super. 2006) (citations omitted) (“We will not ordinarily consider any issue if it has not been set forth in or suggested by an appellate brief’s statement of questions involved, and any issue not raised in a statement of matters complained of on appeal is deemed waived.”); In re W.H., 25 A.3d 330 , 339 n.3 (Pa. Super. 2011), appeal denied, 24 A.3d 364 (Pa. 2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa. -3- J-S76016-17 We review Father’s issue mindful of our well-settled standard of review. | 2 | 4 |
In Re ALDgreen2 sentences2019Thus, he states that “there was insufficient evidence to demonstrate [he] wanted to relinquish his parental rights to his [C]hildren as evidenced by his actions and the goals that he had accomplished.” Id. 2019To the contrary, those grounds may include acts of refusal as well as incapacity to perform parental duties.” In re A.L.D., 797 A.2d 326, 337 (Pa. Super. 2002) (citations omitted). -7- J-S08001-19 The main thrust of Father’s argument centers on his allegation that DHS failed to provide clear and convincing evidence to support the termination of his parental rights, namely, that the “causes of the incapacity, abuse, neglect or refusal [were] not … remedied.” Father’s brief at 6. | 2 | 4 |
| Gb v. Mmbgreen | 2 | 3 |
| R.K.J. v. S.P.K.green | 2 | 3 |
| Estate of Whitleygreen | 2 | 2 |
| Matter of Adoption of Charles EDM, IIgreen | 2 | 2 |
| Adoption of: B.G.S., Appeal of: S.S.green | 2 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
K.W. v. S.L.
green
2 sentences2023Id. at 502-04 . 2017As we recently reiterated in K.W., supra, at 504-505 , “The term in loco par-entis literally means ‘in the place of a parent.’ ” (quoting Peters v. Costello, 586 Pa. 102 , 891 A.2d 705, 710 (2005)). | 6 | 2017–2023 |
| Delaware Valley Landscape Stone v. RRQ, LLC green | 3 | 2023–2023 |
| In Re Adoption of J.M. green | 3 | 2016–2022 |
| Gruber v. Gruber green | 3 | 2002–2004 |
| Doran v. Doran green | 3 | 2003–2003 |
| Commonwealth v. Pagan green | 2 | 2019–2023 |
| In Re BLW green | 2 | 2008–2023 |
| In Re SDT, Jr. green | 2 | 2019–2023 |
| J.M. v. K.W. green | 2 | 2021–2022 |
| In re T.S. green | 2 | 2020–2021 |
| D.K. v. S.P.K. green | 2 | 2019–2021 |
| In the Interest of R.J.T. green | 2 | 2018–2018 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.