In the Matter of: J.C.A.S., a Minor

J-A15022-26 NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37 IN THE MATTER OF: J.C.A.S., A : IN THE SUPERIOR COURT OF MINOR : PENNSYLVANIA : : APPEAL OF: M.S., MOTHER : : : : : No. 214 MDA 2026 Appeal from the Decree Entered January 7, 2026 In the Court of Common Pleas of Dauphin County Orphans' Court at No(s): 126-ad-2025 IN THE MATTER OF: J.C.S., JR., A : IN THE SUPERIOR COURT OF MINOR : PENNSYLVANIA : : APPEAL OF: M.S., MOTHER : : : : : No. 215 MDA 2026 Appeal from the Decree Entered January 7, 2026 In the Court of Common Pleas of Dauphin County Orphans' Court at No(s): 127-AD-2025 BEFORE: KUNSELMAN, J., LANE, J., and FORD ELLIOTT, P.J.E.* MEMORANDUM BY LANE, J.: FILED OCTOBER 22, 2026 M.S. (“Mother”) appeals from the decrees which terminated her parental rights to her two children: J.C.A.S. (born in 2015); and J.C.S., Jr. (born in 2016) (collectively “the Children”). Additionally, Mother’s court-appointed counsel, Michael Farabella, Esquire (“Counsel”), has filed a brief styled ____________________________________________ * Retired Senior Judge assigned to the Superior Court. J-A15022-26 pursuant to Anders v. California, 386 U.S. 738 (1967), as well as an application to withdraw as counsel. After careful review, we defer a ruling on Counsel’s application, and remand to the orphans’ court with instructions. The orphans’ court summarized the factual and procedural history of this matter as follows: . . . On September 17, 2024, the [Dauphin County Social Services for Children and Youth (hereinafter “the Agency”)] was informed by the Pennsylvania State Police (“PSP”) that Mother was publicly intoxicated and acting erratically. Concerns were also reported regarding improper management of J.C.A.S.’s Type 1 diabetes. Late on September 17, 2024, in conjunction with PSP, the Agency visited the home and found Mother visibly intoxicated, unable to form complete sentences, and unable to care for the Children. Mother’s older child, who was present at the house, reported that he was the primary caregiver for the subject Children. The older child also was very knowledgeable regarding the management of J.C.A.S.’s diabetes, whereas Mother was unable to describe his medical needs or treatment. Mother reported that the family had recently moved to Dauphin County after having been evicted from their home in Philadelphia, and because she had not yet established insurance in Dauphin County, she had been going door to door to ask for money to purchase J.C.A.S.’s insulin. Following the home visit, law enforcement officers took the subject Children into protective custody and placed them in the temporary care and custody of the Agency. On September 19, 2024, Mother was admitted into Gaudenzia Coal Township drug and alcohol rehabilitation facility. On October 2, 2024, following an adjudication & disposition (“A&D”) hearing, the Children were adjudicated dependent and placed in formal foster care. On October 19, 2024, Mother was successfully discharged from Gaudenzia and was transitioned to a halfway house in Ashland, PA. On January 23, 2025, one of Mother’s children reported that Mother had been an alcoholic for the entirety of her Children's lives and the longest she had been continuously sober was a year -2- J-A15022-26 at maximum. On January 27, 2025, Mother had a visit with the Children and brought them food from McDonald’s. Reportedly, when the Children returned from the visit, J.C.A.S.’s blood sugar level was not at an appropriate range because Mother had not monitored his sugar level during the visit. On February 22, 2025, Mother left her halfway house to go to work. On the way to work, she stopped at a store and purchased multiple cans of alcohol which she drank on her way to work. She reportedly appeared for work intoxicated, and her employer called the halfway house to come and pick her up. Upon returning to the halfway house, Mother self-discharged from the facility. On February 24, 2025, Mother was arrested in Dauphin County and charged with public drunkenness and disorderly conduct. On March 10, 2025, Mother was re-admitted to Gaudenzia Coal Township for inpatient treatment. However, on March 18, 2025, Mother was placed on a behavioral contract at the facility due to inappropriate comments to staff and clients, fraternizing, failing to appear for group meetings, and being disruptive in group meetings. On March 30, 2025, Mother was taken to pick up her belongings from the Swatara Police Department. On the way back to her facility, Mother asked to stop at a convenience store to use the restroom, and while she was in the store, she stole a can of alcohol and drank it in the restroom. Reportedly, her driver caught her with the can, and upon return to Gaudenzia Coal Township, she was administered a breathalyzer test which recorded that she was under the influence of alcohol. As a result of the incident that occurred on March 30, 2025, Mother was transported to a new inpatient facility called Gaudenzia Common Ground. While there, she was placed on a behavioral contract for failing to keep her hands to herself and not maintaining appropriate boundaries with peers and staff. She also reportedly refused her medication on at least one occasion. On April 23, 2025, Mother was unsuccessfully discharged from Gaudenzia Common Ground after violating her behavioral contract multiple times. On May 1, 2025, an Agency caseworker visited the Children’s foster home. There, it was reported that Mother stated -3- J-A15022-26 she would not be going back to a rehabilitation facility. It was also reported that during Mother’s most recent phone call visit, the Children refused to speak with Mother. Later the same day, Mother contacted an Agency caseworker and reported that she was currently residing in Maryland. On June 11, 2025, an Agency caseworker completed another visit to the Children’s foster home. There, it was reported that Mother had not been attempting to call the Children. On July 23, 2025, the caseworker again visited the Children’s foster home where it was reported that Mother had not contacted the Children at any time within the last month. Later that same day, Mother contacted an Agency caseworker and reported that she was currently residing in her vehicle, renting rooms, and staying in hotels. On July 25, 2025, it was reported that Mother attempted to call the Children, but they did not wish to speak to her. Throughout the life of this case, three (3) permanency review hearings were held on February 20, 2025; May 22, 2025; and September 16, 2025, respectively. At the February 20, 2025 hearing, Mother was removed from the proceeding due to repeated use of inappropriate language despite repeated warnings by the hearing examiner. Following the September 16, 2025 permanency review hearing, th[e] court found that aggravated circumstances regarding Mother, and the Agency was relieved of reasonable efforts for reunification. At each of the three (3) permanency review hearing, the Children were found to be dependent and continued to be placed in Agency care and custody. On November 21, 2025, the Agency filed petitions for involuntary termination of Mother’s parental rights to the Children. [The Agency also filed petitions to terminate the parental rights of the Children’s biological father.] **** On January 7, 2026, th[e] court conducted a hearing (hereinafter “the TPR hearing”) on the Agency’s petitions for involuntary termination of Mother’s parental rights. [The attorney who represented the Children during the dependency proceedings, as their guardian ad litem, Paul Muller, Esquire (“Attorney Muller”) appeared at the TPR hearing and requested to also represent the Children’s legal interests. The orphans’ court questioned Attorney -4- J-A15022-26 Muller as to whether he discerned any conflict between the Children’s best and legal interests, and he indicated that there was no conflict. See N.T., 1/7/26, at 3. Accordingly, the orphans’ court ruled that Attorney Muller could represent the Children’s best and legal interests at the TPR hearing. Mother did not appear at the hearing and did not present any testimony or evidence in opposition to the petitions.] **** At the TPR hearing, the Agency presented the testimony of Jena Brezgel (“Brezgel”)], the Agency caseworker assigned to the instant matter. Brezgel recounted that the Children in this case were placed into Agency care in August 2024, due to homelessness, mental health concerns, substance use concerns, and neglect. [N.T., 1/7/26, at] 4. . . . Specifically, the Children’s situation came to the attention of authorities when J.C.A.S. went around asking for money so that he could buy insulin for himself. [Id.] at 14. Brezgel was asked about the various service objectives Mother was ordered to complete following the [A&D] hearing on October 2, 2024. Brezgel recounted that Mother’s service objectives were as follows: (a) to cooperate and comply with the Agency; (b) to complete a drug and alcohol evaluation and follow all recommendations; (c) to provide random urine screens requested from the Agency; (d) complete a parent psychological evaluation and follow all recommendations; (e) to learn and demonstrate appropriate skills and care for the treatment of J.C.A.S.’s diabetes; (f) to ensure that the Children receive all necessary medical, dental, mental health and educational needs; (g) to demonstrate an ongoing commitment while the Children are in placement; (h) to obtain and maintain an adequate income/benefits to meet the needs of the family; (i) to obtain and maintain stable, sanitary and appropriate housing for the family; (j) to attend counseling to address the domestic violence between the parents if they decide to live together; (k) to attend all court hearings, Agency meetings and treatment plan meetings; (l) to sign all release of information forms requested by the Agency; and (m) to notify the Agency within 24 hours of new residence or contact information. Regarding Mother’s objective to maintain visitation and contact with the Children, Brezgel reported that Mother had -5- J-A15022-26 several visits with the Children but was not able to visit the Children regularly . . . because she was in and out of inpatient drug treatment facilities and did not maintain consistent phone numbers that the Agency could use to contact her. [Id.] at 7-8. During her first few visits with the Children, Mother would bring snacks and fail to regulate what J.C.A.S. ate, causing his blood sugars to be very high. [Id.] at 8. Brezgel stated that Mother’s most recent visit with the children was in October of 2025. [Id.] at 7. During that visit, the Children did not seem interested in visiting with Mother and did not acknowledge her when she entered the room. [Id.] at 8. Any time conversation was initiated, it was initiated by Mother and not the Children. [Id.] at 8. Brezgel reported that since October 2025, there have been some phone calls between Mother and the Children, but during those calls, the Children would talk with Mother for just a few minutes and then would be ready for the calls to be over. [Id.] at 21. Brezgel testified that Mother has failed to learn and demonstrate appropriate skills and care for the treatment of J.C.A.S.’s diabetes. Brezgel stated that Mother never attended treatment meetings or medical appointments for J.C.A.S., and she did not have any understanding or ability to care for J.C.A.S.’s diabetes. [Id.] at 8. According to Brezgel, Mother scheduled two educational sessions with the endocrinology department Penn State Health, but she failed to attend either one. [Id.] at 8, 19. Mother . . . completed a psychological evaluation on December 29, 2025. [Id.] at 9. However, Brezgel reported that Mother has not exhibited any progress regarding her drug and alcohol treatment. While she completed a drug and alcohol assessment, she was unsuccessfully discharged from three or four inpatient treatment facilities. [Id.] at 9-10, 14. Recently, the Agency referred Mother for an evaluation with Dauphin County Drug and Alcohol, where it was recommended that she participate in outpatient therapy. [Id.] at 10. Mother has reported to Brezgel that she is attending outpatient therapy, but Mother has not signed a release to permit the treatment facility to speak with the Agency, so the Agency has not been able to confirm Mother’s attendance at that facility or confirm whether she has completed the outpatient program. [Id.] at 10. Moreover, Mother has consistently failed to provide urine screens when requested by the Agency. According to Brezgel, throughout the life of this case, the -6- J-A15022-26 Agency has requested 42 urine screens, and Mother has only provided two of those. [Id.] at 10. Brezgel testified that she is unaware whether Mother currently has a home address, and from what she last heard, Mother was living in her car. [Id.] at 14. Mother has never provided Brezgel with a physical address. [Id.] at 14. Brezgel reported that Mother has moved in and out of Pennsylvania several times, and as recently as May 2025, Mother was living in Maryland. [Id.] at 15. According to Brezgel, the Children no longer wish to have contact with Mother and that it was the Children's choice to break off contact with Mother because the calls she had with them were not good or appropriate. [Id.] at 15. Brezgel stated that she has visited the Children in their foster home, and they are doing well there. [Id.] at 11. The foster parents know how to monitor J.C.A.S.’s diabetes and take the Children to all necessary medical appointments. [Id.] at 11. Moreover, the Children are doing well in school, and both are involved in wrestling. [Id.] at 12. The subject Children get along with the other children in the foster parents’ home, and the subject Children refer to the foster parents as mom and dad. [Id.] at 12. Brezgel reported that she is satisfied with the care the foster parents are giving the Children, and that the foster parents have expressed a desire to be permanent resources for the Children. [Id.] at 12. On January 7, 2026, [at the conclusion of the TPR hearing], th[e] court concluded that the Agency had satisfied its burden of establishing, by clear and convincing evidence, that statutory grounds existed for termination of Mother’s parental rights to the Children and issued decrees terminating Mother’s parental rights to the Children [pursuant to 23 Pa.C.S.A. §§ 2511(a)(1), (2), (5), (8), and (b)]. [The court also issued decrees terminating the parental rights of the Children’s biological father.] On February 5, 2026, Mother, through counsel, filed notices of appeal to the Superior Court at each of the above-captioned dockets. Mother, however, did not file a statement of errors complained of on appeal [pursuant to Pa.R.A.P. 1925(a)(2)(i) and (b)] at either docket. Instead, Mother’s counsel filed a statement of intent to file an Anders . . . brief in lieu of filing a concise statement of matters on appeal. On February 24, 2026, th[e] court filed a statement in lieu of a [Rule] 1925[(a)] opinion. Therein, th[e] court expressed that -7- J-A15022-26 it would refrain from issuing a [Rule] 1925[(a)] opinion because Mother’s Counsel had not filed a statement of errors complained of on appeal and instead filed a statement of intent to file an Anders . . . brief. However, on July 22, 2026, the Superior Court issued an order directing the [orphans’] court to file a [Rule] 1925[(a)] opinion, addressing the statutory grounds upon which th[e] court terminated Mother’s parental rights as to each child. The [orphans’ court then filed a Rule 1925(a) opinion. Thereafter, Counsel filed an updated Anders brief.] Orphans’ Court Opinion, 8/21/26, at 2-9 (unnecessary capitalization omitted, some capitalization added). When faced with an Anders brief, this Court may not review the merits of any underlying issues without first examining counsel’s request to withdraw. See In re X.J., 105 A.3d 1, 3 (Pa. Super. 2014). As this Court has explained, in order to withdraw pursuant to Anders, counsel must: 1) petition the court for leave to withdraw stating that, after making a conscientious examination of the record, counsel has determined that the appeal would be frivolous; 2) furnish a copy of the [Anders] brief to the [appellant]; and 3) advise the [appellant] that he or she has the right to retain private counsel or raise additional arguments that the [appellant] deems worthy of the court's attention. With respect to the third requirement of Anders, that counsel inform the appellant of his or her rights in light of counsel’s withdrawal, this Court has held that counsel must “attach to their petition to withdraw a copy of the letter sent to their client advising him or her of their rights.” In re J.D.H., 171 A.3d 903, 907 (Pa. Super. 2017) (citations and quotation marks omitted). -8- J-A15022-26 Additionally, counsel must file a brief that meets the following requirements established by the Pennsylvania Supreme Court in Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009): (1) provide a summary of the procedural history and facts, with citations to the record; (2) refer to anything in the record that counsel believes arguably supports the appeal; (3) set forth counsel’s conclusion that the appeal is frivolous; and (4) state counsel’s reasons for concluding that the appeal is frivolous. Counsel should articulate the relevant facts of record, controlling case law, and/or statutes on point that have led to the conclusion that the appeal is frivolous. X.J., 105 A.3d at 3-4 (citation omitted). “Once counsel has satisfied the above requirements, it is then this Court’s duty to conduct its own review of the trial court’s proceedings and render an independent judgment as to whether the appeal is, in fact, wholly frivolous.” Id. at 4 (citations omitted). Our independent review is not limited to the issue(s) discussed by Anders counsel, but extends to “additional, non- frivolous issues” that may have been overlooked by counsel. J.D.H., 171 A.3d at 908 (citation omitted). An appeal is frivolous when it “lacks any basis in law or fact.” Santiago, 978 A.2d at 356 (citation omitted). In this matter, Counsel filed an application to withdraw indicating his conscientious review of the cases and his determination that Mother’s appeals are frivolous. Counsel also filed an Anders brief which included a summary of the factual and procedural history of the case with citations to the record, discussion of the issues that could arguably support Mother’s appeals, and Counsel’s explanation for his belief that Mother’s appellate claims are -9- J-A15022-26 frivolous, with citations to relevant legal authority. Finally, Counsel attached to his petition the letter that he sent to Mother which advised her of her rights to: (1) retain new counsel to pursue the appeals; (2) proceed pro se on the appeals; and (3) raise any additional points that Mother deems worthy of this Court’s attention. As Counsel has met the technical requirements of Anders and Santiago, we will proceed to consider the issues that Counsel has identified. In the Anders brief, Counsel identifies the following issues for our review: I. Did the [orphans’] court abuse its discretion in terminating [the] parental rights of Mother where the agency failed to meet its burden of proof? II. Did the [orphans’] court abuse its discretion by failing to give primary consideration to the developmental, physical, emotional needs, and welfare of the child? Anders Brief at 6 (unnecessary capitalization omitted). Our standard of review in termination of parental rights cases is well established: In cases concerning the involuntary termination of parental rights, appellate review is limited to a determination of whether the decree of the termination court is supported by competent evidence. When applying this standard, the appellate court must accept the trial court’s findings of fact and credibility determinations if they are supported by the record. Where the trial court’s factual findings are supported by the evidence, an appellate court may not disturb the trial court’s ruling unless it has discerned an error of law or abuse of discretion. An abuse of discretion does not result merely because the reviewing court might have reached a different conclusion or the - 10 - J-A15022-26 facts could support an opposite result. Instead, an appellate court may reverse for an abuse of discretion only upon demonstration of manifest unreasonableness, partiality, prejudice, bias, or ill- will. This standard of review reflects the deference we pay to trial courts, who often observe the parties first-hand across multiple hearings. In considering a petition to terminate parental rights, a trial court must balance the parent’s fundamental right to make decisions concerning the care, custody, and control of his or her child with the child’s essential needs for a parent’s care, protection, and support. Termination of parental rights has significant and permanent consequences for both the parent and child. As such, the law of this Commonwealth requires the moving party to establish the statutory grounds by clear and convincing evidence, which is evidence that is so clear, direct, weighty, and convincing as to enable a trier of fact to come to a clear conviction, without hesitance, of the truth of the precise facts in issue. Interest of M.E., 283 A.3d 820, 829-30 (Pa. Super. 2022) (cleaned up). The involuntary termination of parental rights is governed by section 2511 of the Adoption Act,1 which calls for a bifurcated analysis that first focuses upon the “eleven enumerated grounds” of parental conduct set forth in section 2511(a) that may warrant termination. Id. at 830; see also 23 Pa.C.S.A. § 2511(a)(1)-(11). If the orphans’ court determines the petitioner has established grounds for termination under one of the section 2511(a) subsections by “clear and convincing evidence,” the court then assesses the petition pursuant to section 2511(b), which focuses upon the child’s developmental, physical, and emotional needs and welfare. In re T.S.M., 71 A.3d 251, 267 (Pa. 2013); see also 23 Pa.C.S.A. § 2511(b). This Court need ____________________________________________ 1 See 23 Pa.C.S.A. §§ 2101 et seq. - 11 - J-A15022-26 only agree with the orphans’ court’s determination as to any one subsection of section 2511(a), in addition to section 2511(b), in order to affirm termination. See M.E., 283 A.3d at 830 (citing In re B.L.W., 843 A.2d 380, 384 (Pa. Super. 2004) (en banc)). In this case, the orphans’ court terminated Mother’s parental rights to the Children pursuant to section 2511(a)(1), (2), (5), (8), and (b). Given our latitude in the review of an orphans’ court’s findings under section 2511(a), we elect to review the underlying decrees pursuant to section 2511(a)(1) and (b), which provide as follows: (a) General Rule.—The rights of a parent in regard to a child may be terminated after a petition filed on any of the following grounds: (1) The parent by conduct continuing for a period of at least six months immediately preceding the filing of the petition either has evidenced a settled purpose of relinquishing parental claim to a child or has refused or failed to perform parental duties. **** (b) Other considerations.—The court in terminating the rights of a parent shall give primary consideration to the developmental, physical and emotional needs and welfare of the child. The rights of a parent shall not be terminated solely on the basis of environmental factors such as inadequate housing, furnishings, income, clothing and medical care if found to be beyond the control of the parent. With respect to any petition filed pursuant to subsection (a)(1), (6) or (8), the court shall not consider any efforts by the parent to remedy the conditions described therein which are first initiated subsequent to the giving of notice of the filing of the petition. 23 Pa.C.S.A. § 2511(a)(1), (b). - 12 - J-A15022-26 In the first issue identified in the Anders brief, Counsel addresses the sufficiency of the evidence supporting termination under section 2511(a). Counsel offers support for this issue by contending that Mother initially tried to complete her service objectives. According to Counsel, Brezgel testified that, in terms of Mother’s visitation and maintaining contact with the Children, Brezgel set up visits at the beginning of 2025 which were then reduced to one visit per month by the orphans’ court. Counsel indicates that, in the first few visits, Mother would bring snacks for the Children. Counsel observes that Mother then went into inpatient treatment to get clean, which resulted in delays for visitation. Counsel then explains why he has determined that Mother’s first issue is frivolous. Counsel points out that, during her few visits, Mother would bring snacks for the Children and would allow J.C.A.S. to eat whatever he wanted without monitoring his sugars. Counsel points to Brezgel’s testimony that Mother did not have an understanding of J.C.A.S.’s diabetes. Counsel indicates that, while Mother scheduled two educational appointments with the endocrinologist at Penn State Hershey, she missed both appointments. Counsel contends that one of the reasons for the court’s finding of neglect was due to J.C.A.S. asking for money so he could buy insulin for himself. Counsel further notes Mother’s failure to successfully address her alcoholism, and details that: (1) upon discharge from a rehabilitation facility to a halfway house, Mother’s appeared at work intoxicated, which resulted in - 13 - J-A15022-26 her self-discharging from the facility; (2) two days later, Mother was charged with public drunkenness and disorderly conduct; (3) although Mother did re- admit to a rehabilitation facility, she was moved to another inpatient facility shortly thereafter due to her stealing alcohol from a convenience store and drinking it in the bathroom; (4) Mother was then unsuccessfully discharged from the second facility and stated she would no longer attend drug and alcohol treatment; and (5) of the forty urine screens requested by the Agency, Mother complied with only two. Counsel asserts that, due to Mother missing visits and other appointments, a barrier between her and the Children was created. Counsel points out that Mother failed to attend extracurricular events, failed to attend appointments, and failed to receive education relating to J.C.A.S.’s medical needs. Counsel explains that, during a phone call with the Children and at the last visit in October 2025, the Children did not speak to Mother at all. Counsel notes that Mother attempted to complete her mental health requirements and received a referral for an evaluation in the spring of 2025, but she arrived so late to the appointment that they could not complete the evaluation. According to Counsel, a re-evaluation was to be scheduled after Mother was further along in her drug and alcohol treatment, but since Mother was not successful in continuing her drug and alcohol treatment, a re- evaluation never occurred. Counsel concludes that the Agency presented sufficient evidence by a clear and convincing standard that Mother could not - 14 - J-A15022-26 or would not do what needed to be done for the Children, and that the issues that existed at the time of the Children’s referral to the Agency still existed at the time of the TPR hearing. The orphans’ court explained the reasons underlying its decision to terminate Mother’s parental rights pursuant to section 2511(a)(1), as follows: [Section] 2511(a)(1) allows for the termination of parental rights when “[t]he parent by conduct continuing for a period of at least six months immediately preceding the filing of the petition either has evidenced a settled purpose of relinquishing parental claim to a child or has refused or failed to perform parental duties.” [This court] believe[s] that the testimony presented at the TPR hearing in this matter demonstrated that Mother had evidenced a settled purpose of relinquishing parental claim to the Children for a period of at least six months immediately preceding the Agency’s filing of the TPR petition[s]. In the nearly seventeen (17) months between the initiation of this case and the date of the TPR hearing, Mother has been in and out of multiple inpatient drug and alcohol rehabilitation facilities, each time being discharged unsuccessfully due to behavioral issues and her unwillingness to constructively participate in the programs; and in some cases, she has even exhibited surreptitious relapses in alcohol use while she is away from the facility and being unsupervised. Additionally, Mother refused to appear for 40 out of 42 drug screenings that the Agency requested throughout the life of this case, and while Mother claims that she has recently been participating in outpatient drug and alcohol counseling, she has refused to sign the releases necessary to allow for the facilities to speak to the Agency and confirm her participation there. Moreover, Mother has failed to demonstrate that she can maintain appropriate housing or financial stability throughout the life of this case. It has been reported that she was going back and forth between Pennsylvania and Maryland, and she has never provided the Agency with a physical address of a residence. As of July 2025, it was reported to the Agency that Mother was living out of her car, renting rooms, and staying in different hotels. - 15 - J-A15022-26 Mother’s visitation with the Children has been limited due to her inability to adequately address her alcohol use and maintain stable housing. And in the few times that she has visited with the Children, the Children were hesitant to communicate with her, and Mother demonstrated a lack of knowledge of the Children’s unique needs, particularly those of J.C.A.S., who suffers from Type 1 diabetes. Mother on several occasions provided J.C.A.S. with meals that were inappropriate for his condition, and which raised his blood sugar to concerning levels. Mother has also failed to attend any of the Children’s medical appointments, and while she scheduled two educational sessions to learn more about J.C.A.S.’s diabetes and his requisite care, she failed to attend either of those sessions. In sum, Mother’s continued refusal to take responsibility for her alcohol use; her consistent ejection from inpatient treatment programs; her consistent refusal to appear for drug screenings; her inability to maintain stable housing; and her failure to take an interest in and learn more about her Children’s medical conditions clearly evidenced a settled purpose of relinquishing parental claim to a child was well as an unwillingness to take the steps necessary for her to effectively perform her parental duties. Therefore, the termination of her parental rights was appropriate under [section] 2511(a)(1). Orphans’ Court Opinion, 8/21/26, at 11-13 (unnecessary capitalization omitted, some capitalization added). Based on our review, we conclude that the orphans’ court’s determination that the Agency established the requirements of section 2511(a)(1) by clear and convincing evidence is supported by the record. As explained above, pursuant to subsection (a)(1), the Agency was required to establish that Mother “by conduct continuing for a period of at least six months immediately preceding the filing of the petition either has evidenced a settled purpose of relinquishing parental claim to a child or has refused or failed to perform parental duties.” 23 Pa.C.S.A. § 2511(a)(1). In making this - 16 - J-A15022-26 assessment, the orphans’ court was not permitted to consider any efforts made by Mother to remedy the conditions after the filing of the TPR petitions. See 23 Pa.C.S.A. § 2511(b). Here, the Agency filed the TPR petitions on November 21, 2025. The evidence of record reflects that, in the six months preceding the filing of those petitions, Mother either refused or failed to perform parental duties. While Mother was provided with a list of service objectives, she failed to comply with those objectives. Specifically, Brezgel recounted that Mother’s service objectives were: (a) to cooperate and comply with the Agency; (b) to complete a drug and alcohol evaluation and follow all recommendations; (c) to provide random urine screens requested from the Agency; (d) complete a parent psychological evaluation and follow all recommendations; (e) to learn and demonstrate appropriate skills and care for the treatment of J.C.A.S.’s diabetes; (f) to ensure that the Children receive all necessary medical, dental, mental health and educational needs; (g) to demonstrate an ongoing commitment while the Children are in placement; (h) to obtain and maintain an adequate income/benefits to meet the needs of the family; (i) to obtain and maintain stable, sanitary and appropriate housing for the family; (j) to attend counseling to address the domestic violence between the parents if they decide to live together; (k) to attend all court hearings, Agency meetings and treatment plan meetings; (l) to sign all release of information forms - 17 - J-A15022-26 requested by the Agency; and (m) to notify the Agency within 24 hours of new residence or contact information. In the six months prior to the filing of the TPR petitions, Mother did not cooperate or comply with the Agency’s directives, did not provide forty of the forty-two random urine screens requested from the Agency, did not complete a parent psychological evaluation,2 did not learn and demonstrate appropriate skills and care for the treatment of J.C.A.S.’s diabetes, did not ensure that the Children received all necessary medical, dental, mental health and educational needs, did not demonstrate an ongoing commitment while the Children were in placement, did not obtain and maintain an adequate income/benefits to meet the needs of the family, did not obtain and maintain stable, sanitary, and appropriate housing for the family, did not attend counseling to address the domestic violence between the parents, did not attend all court hearings, Agency meetings, and treatment plan meetings, did not sign all release of information forms requested by the Agency, and never provided the Agency with a physical address.3 Thus, as the record supports the orphans’ court’s ____________________________________________ 2 While Mother did eventually complete a psychological evaluation, she did so on December 29, 2025, which was after the TPR petitions had been filed. Thus, the orphans’ court was not permitted to consider this information when considering section 2511(a)(1). See 23 Pa.C.S.A. § 2511(b). 3 Although Mother initially completed a drug and alcohol evaluation, she was unsuccessfully discharged from at least two rehabilitation facilities and failed to successfully complete any drug and alcohol treatment program in the six months prior to the filing of the TPR petitions. - 18 - J-A15022-26 finding of grounds for termination under section 2511(a)(1), we affirm this ruling at both dockets. In the second issue identified in the Anders brief, Counsel challenges the trial court’s ruling with respect to section 2511(b). Having agreed with the orphans’ court as to one of the enumerated subsections of section 2511(a), we would ordinarily turn our attention to the court’s analysis of section 2511(b). See T.S.M., 71 A.3d at 267 (holding that if the orphans’ court determines the petitioner has established grounds for termination under one of the section 2511(a) subsections