In Re Adoption of Durham

SPAETH, Judge:

This appeal is from an order involuntarily terminating appellant’s parental rights to her three children. We have concluded that the trial court applied an incorrect standard of proof, and unduly restricted the evidence. We therefore reverse and remand for a new hearing.

In Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982), the Court held that parental rights may not be involuntarily terminated except upon at least clear and convincing evidence. In In Re Adoption of M.E.T., 313 Pa.Super. 316, 459 A.2d 1247 (1983), we held

that any case in which a party’s…