Matter of K.J.L. v C.L. centers on the Bronx County Family Court’s decision to terminate a mother’s parental rights after her children had spent over three years in foster care. At the heart of the matter was whether the mother had demonstrated meaningful progress in resolving the issues that had led to her children’s removal, and whether it remained in their best interests to delay permanency in the hope of reunification.
The children, one of whom is autistic and nonverbal, entered care in March 2021 at the ages of nine and six. Over time, they were placed in separate foster homes where they received consistent care, support, and structure. Both foster families ultimately expressed a desire to adopt. From the outset, the mother was provided with a detailed and supportive service plan designed to address the circumstances that had jeopardized her custody. That plan required her to engage in substance abuse and mental health treatment, submit to randomized drug testing, complete parenting classes tailored to special needs children, permit home inspections by caseworkers, and maintain consistent visitation with her children.
Despite having ample time and resources to comply, the mother did not complete these key components of her plan. While there were moments of positive interaction with the children during supervised visits, the court found these were insufficient when measured against the broader, persistent failure to make progress toward reunification. The record reflected a sustained inability or unwillingness to create the foundation for a stable and secure home.
The Family Court rejected the mother’s request for a suspended judgment—a form of delayed final decision—finding no reasonable basis to believe that additional time would lead to a different outcome. The court concluded that the children’s need for permanency, after years in limbo, outweighed the tenuous possibility of future compliance.
One of the few unresolved issues involved the older child’s expressed wish to return to his mother’s care. His attorney requested that the case be reopened for further consideration based on that desire. However, the court declined, noting that the child was under the age of fourteen and his legal consent was not required for adoption. Moreover, there was no indication that the mother’s circumstances had materially changed or that the children’s current placements had become unsuitable.
Ultimately, the AD1 affirmed the outcome, emphasizing the principle that a child’s best interests must guide outcomes in these proceedings. In this case, the court determined that the only responsible path forward was to ensure the children could remain in homes that met their needs and offered a clear path to permanency.
Parenting plans aren’t wish lists—they’re mandates with consequences.
# # #
DECISION