Patricia A.F. v. James R.F.

HERRMANN, Chief Justice:

This appeal requires the review of a Family Court order terminating the parental rights of the natural mother over the daughter, a minor child. The Trial Court found “that the petitioner has proved that the mother is unable to plan adequately for the child’s physical needs or her mental or emotional health and development [13 Del.C. § 1103(5) ] 1 and that, therefore, it would be in the child’s best interests to terminate the mother’s parental rights (13 Del.C. § 1108).” 2

While the Trial Court did not specify, the then existing standard of proof in a termination of…