In re Adoption of a Child by C.J. required the Appellate Division to assess whether the Chancery Court properly found that a biological mother failed to affirmatively assume the duties of a parent. The Court began by noting that the termination of parental rights implicates fundamental liberty interests, which are protected by the United States Constitution. Here, the Court ruled that the lower court improperly held that the biological mother failed to financially support the child and failed to show a continued interest in the child. The Appellate Division held that the biological mother presented evidence showing she was unable to work to support the child and that the lower court’s orders prohibited the mother from engaging in her child’s life. Thus, the lower court’s conclusions were not supported by the record.