In Re Adoption of M.E.T.

CAVANAUGH, Judge:

The issues raised in this appeal relate to the application of the United States Supreme Court’s recent holding in Santosky v. Kramer, Commissioner, Ulster County Dept. of Social Services, et al., 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982), to Pennsylvania cases. The effect of the Santosky decision was to raise the burden of proof required in involuntary termination of parental rights cases from a “preponderance of the evidence” to “clear and convincing evidence.” We now hold that the higher burden of proof required by Santosky must be applied to all cases which had…