New Jersey Division of Youth & Family Services v. G.L.

On this appeal we revisit the issue that we recently addressed in New Jersey Division of Youth and Family Services v. M.M., 189 N.J. 261, 914 A.2d 1265 (2007): When may a parent be subjected to the termination of her parental rights for failing to eliminate harm to the child posed by her spouse?

I

The parties in this parental termination action are Gloria Lynch and her daughter Mary Jane Carleton whose father is Gloria’s husband Ted Carleton.1 Ted and Gloria were also the parents of an older son, Isaac, whose death focused the court’s attention on the family. Gloria, who lives with a son from a…