In re Aidan D.

Summary

The New York Appellate Division affirmed an order terminating the respondent’s parental rights after she admitted that her child was permanently neglected. The court held that her knowing, voluntary, and intelligent admissions satisfied the agency’s burden and that the termination disposition was supported by substantial evidence concerning the child’s best interests.

Holdings

1. When a parent admits to permanent neglect, the agency need not present evidence establishing that it exercised diligent efforts to strengthen the parental relationship, and the court need not determine that issue.
2. Family Court properly accepted respondent's admission because it was knowing, voluntary, and intelligent, made in open court with the active assistance and consultation of counsel, and respondent's admissions concerning housing and permanency-planning meetings independently supported permanent neglect.
3. Termination of respondent's parental rights was the appropriate disposition because it served the child's best interests and was supported by a sound and substantial basis in the record.

Questions Presented

1. Whether Family Court properly accepted respondent's admission to permanent neglect.
2. Whether respondent's admission was sufficient without proof of the agency's diligent efforts to strengthen the parental relationship.
3. Whether termination of respondent's parental rights was supported by the child's best interests and the record.

Disposition

affirmed