Jackson v. DFS

Summary

The Supreme Court of Delaware affirmed the termination of Matthew Jackson’s parental rights because clear and convincing evidence established statutory grounds for termination and showed that termination served the child’s best interests. Although the Family Court improperly treated the failure-to-plan ground as established solely by the custody presumption and the excusal from reunification services, the felony-conviction and prior-involuntary-termination grounds independently supported termination. The Court also upheld the Family Court’s best-interests findings concerning domestic violence and Jackson’s criminal history.