Dept. of Social Serv. v. Headden

Summary

The court affirmed, as modified, the termination of the mother's parental rights based on her willful failure to visit and support her child and the child's best interests. It held that the record contained clear and convincing evidence that the mother's prolonged lack of contact and support reflected a settled purpose to forego parental duties, despite her later efforts. The court declined to decide whether termination could rest solely on the child's placement in foster care for 15 of the most recent 22 months.