## Facts

- R.J.T., a minor child, was removed from his parents’ custody about one month after birth due to a history of domestic violence and substance abuse and was adjudicated dependent.
- The child was placed in foster care, and the initial permanency goal was reunification.
- Over roughly two years in placement (about 22 months), the county agency sought to change the permanency goal from reunification to adoption.
- The juvenile court denied the requested goal change and maintained reunification, citing parental progress on objectives and concerns requiring further evaluation of the foster placement and the child’s bond with the foster parents.
- The intermediate appellate court reversed, concluded the juvenile court abused its discretion, and directed a change of goal to adoption, treating the 15-of-22-month benchmark as effectively requiring a goal change when reunification was not imminent.
- The state supreme court granted review; the child was nearly four years old at the time of its decision.

## Issues

1. Whether the intermediate appellate court misapplied the abuse-of-discretion standard by reweighing evidence and substituting its judgment for the juvenile court’s credibility determinations in a permanency goal-change decision.
2. Whether the 15-of-22-month foster-care benchmark requires an automatic change of permanency goal from reunification to adoption, or instead is only one factor within the statutory permanency-hearing analysis.

## Decision

- The state supreme court reversed the intermediate appellate court and reinstated the juvenile court’s order maintaining reunification as the permanency goal.
- The court held the juvenile court did not abuse its discretion in denying the agency’s request to change the goal to adoption.
- The court held the 15-of-22-month benchmark does not mandate an automatic goal change to adoption; it triggers statutory inquiries but does not replace individualized findings under the permanency-hearing factors.
- The court concluded the intermediate appellate court erred by treating the benchmark as outcome-determinative and by relying on evidence the juvenile court did not credit.

## Legal Principles

- Appellate review of dependency permanency decisions is for abuse of discretion; appellate courts must not reweigh evidence or disturb supported credibility determinations.
- The duration of foster-care placement (including the 15-of-22-month benchmark) is not a mechanical trigger requiring a goal change to adoption; it is one consideration within the permanency-hearing framework.
- Permanency goal decisions require individualized findings focused on the child’s best interests, including parental compliance and progress, safety, and the appropriateness and feasibility of the current placement.

## Conclusion

The court reinstated the juvenile court’s refusal to change the child’s permanency goal to adoption, holding that appellate courts must defer absent an abuse of discretion and that the 15-of-22-month benchmark does not compel an automatic goal change without a full, individualized permanency analysis.


In re Interest of R.J.T., 9 A.3d 1179 (Pa. 2010)