In re Jacob W.

Summary

The court affirmed the Appellate Court’s reversal of judgments denying termination petitions concerning the respondent father’s three children. It held that the trial court used the wrong test for determining whether an ongoing parent-child relationship existed by focusing on the father’s conduct rather than the children’s present feelings and memories, and that the trial court clearly erred in finding no evidence that additional time would be detrimental to the children. The matter therefore remained subject to a new termination hearing at which the petitioner retained the burden of proof.