Supreme Court of New Jersey

In the Matter of the Adoption of Children by L.a.s.

August 5, 1993134 N.J. 127

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s reversal of the trial court’s termination of the natural father’s parental rights and remanded for a comprehensive hearing, holding that a parent’s lengthy incarceration is a material factor but cannot alone justify termination; the court must examine abandonment and unfitness in a broader factual context.