Supreme Court of Delaware

Handlon, Colt v. DFS and OCA TPR

February 12, 2026

Summary

The Court affirmed the Family Court’s termination of Father’s parental rights. It held that Father’s unpreserved constitutional challenge was subject to plain-error review and that the Family Court could not have plainly erred by declining to apply strict scrutiny because no binding authority definitively required that approach. The Court also held that the statutory grounds for termination and the children’s best interests were supported by clear and convincing evidence, and that the Family Court did not exceed its discretion.