In re Jacob W.
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The Supreme Court affirmed the judgment of the Appellate Court reversing the judgments of the trial court denying the petitions filed by the maternal grandmother (Petitioner) for termination of Father's parental rights with respect to his three minor children, holding that the trial court applied an incorrect legal test to determine that Petitioner had failed to prove the lack of an ongoing parent-child relationship.
Specifically, the Court held (1) the trial court erred in concluding that, under the facts of this case, it was required to depart from the usual test to determine whether a petitioner has established a lack of an ongoing parent-child relationship; and (2) the trial court’s finding that Petitioner failed to prove that allowing further time to develop a parent-child relationship would be detrimental to the best interests of the children was clearly erroneous.
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