In Matter of G.M.R. (A.R.), the Appellate Division, First Department, affirmed a Family Court’s decision to terminate the respondent father’s parental rights based on a finding of permanent neglect. The case involved multiple children under the age of eighteen and was brought by Good Shepherd Services, a foster care agency, seeking custody and termination of parental rights.
The court found clear and convincing evidence that the agency made diligent efforts to facilitate reunification, as required under Social Services Law § 384-b. These efforts included developing a tailored service plan to address the father’s specific parenting challenges, referring him to appropriate services, scheduling meetings and home visits, and maintaining communication with his service providers. Despite these efforts, the father failed to engage meaningfully with the plan. His argument that the agency should have initiated family therapy was rejected, as the dispositional order made clear that therapy would begin only when clinically appropriate. The children’s therapist determined they were not ready for such sessions, which aligned with precedent that therapy must be guided by clinical judgment.
The court also upheld the finding of permanent neglect, noting that the father had not adequately planned for the children’s future over a period exceeding one year. Although he completed a parenting class, he failed to comply with other critical components of the service plan. He did not complete anger management, refused drug testing, abandoned his substance abuse treatment, and minimized his alcohol issues. These failures were particularly concerning given that the children had been removed due to excessive corporal punishment and alcohol abuse.
The appellate court dismissed the appeal from the fact-finding order as subsumed within the appeal from the dispositional orders. The ruling reinforces the principle that parental rights may be terminated when a parent fails to take meaningful steps toward reunification despite the agency’s sustained efforts.
Sadly, when parenting plans get ignored and therapy’s off the table—termination becomes the final chapter ....
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DECISION