K.D. v. Department of Health & Rehabilitative Services

Appellant, the natural mother of C.N.D., seeks review of a final order terminating her parental rights. She argues that the order must be reversed because the sole justification offered in support of its entry was appellant’s failure substantially to comply with the terms of a performance agreement. We agree.

The only evidence offered in support of termination of appellant’s parental rights at the adjudicatory hearing was that appellant had failed to comply with the terms of a performance agreement which had been approved by the trial court some four months earlier. Likewise, the sole…