In Re the Adoption of Angela E.

Summary

The court held that Father abandoned his children by willfully failing to visit them, despite an earlier order suspending visitation, because he did not pursue reinstatement of visitation for nearly two years. The court held that the evidence did not clearly and convincingly establish abandonment by willful failure to support because Father made substantial payments during the relevant period and the record did not adequately establish that his payments were merely token. The case was remanded for the trial court to determine whether termination was in the children's best interests.