In re S.C. presented the Pennsylvania Superior Court with an appeal on behalf of a young child after the trial court denied a petition seeking to involuntarily terminate both parents’ parental rights. The Court found it problematic that the trial court failed to comply with the required bifurcated analysis required under Section 2511 of the Adoption Act. The Court reiterated that “[i]t is well-settled under Pennsylvania law that the trial court’s analysis under Section 2511(b) is only necessary if grounds for termination exist under Section 2511(a).” The Court held that the agencies acting on behalf of the child established by clear and convincing evidence that he was abused, as required under section 2511(a)(2). And under subsection (b), the Court held that, when weighing all essential best-interest-of-the-child factors, it was in the child’s best interest to terminate both parents’ parental rights.
