William D. Teachem, Below v. Nancy M. Terry, Below

Summary

The court affirmed the termination of the father's parental rights because clear and convincing evidence established intentional abandonment and termination served the child's best interests. It held that intentional abandonment requires a settled purpose to forego parental duties and relinquish parental claims, but does not require a continuing intent to abandon through the filing of the petition. The court identified errors in the Family Court's analyses of abandonment without intent and failure to plan, but found those errors harmless because intentional abandonment independently supported termination.