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In re M.N.K.

Pennsylvania Superior Court

January 6, 2022

The Pennsylvania Superior Court affirmed an order of the Orphans’ Court, terminating the appellant’s parental rights. The issue was procedural. The appellant argued that he was not adequately served with the petition for involuntary termination under 23 Pa.C.S. § 2513 and Pennsylvania Orphans’ Court Rule 15.6. The appellant was notified of the hearing while virtually attending a prior hearing. And service was sent to his address by certified mail, though no adult signed for it. Instead, the postal worker made a notation that it was delivered. The appellant argued that there was no personal service. The Superior Court court held that the appellant had proper notice, notwithstanding any perceived defect.

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