## Facts

- S.G.T.’s mother married appellant when S.G.T. was three years old.
- Two years later, S.G.T.’s mother died in an automobile accident, and appellant later completed the adoption of S.G.T.
- In 1979, the Hall County Department of Family & Children Services (DFCS) received reports that S.G.T. was being physically abused.
- During the investigation, a DFCS caseworker observed appellant’s open hostility toward S.G.T., including ridicule of the child; the investigation also included reports of bruising and school problems.
- The DFCS matter was closed after the caseworker failed to make home visits and the case did not progress.
- In February 1981, DFCS reopened the matter after school officials reported that nine-year-old S.G.T. had an injury.
- On February 3, 1981, S.G.T. ran away because he feared punishment for a poor report card.
- When law enforcement contacted appellant, he indicated he was willing for S.G.T. to spend the night in jail.
- Later that night, in S.G.T.’s presence, appellant offered to relinquish his parental rights.
- Appellant later signed a consent to S.G.T.’s adoption but withdrew the consent.
- S.G.T. was placed with his maternal grandparents under DFCS involvement while DFCS pursued termination.
- At trial, S.G.T. was 12 years old; witnesses included S.G.T., his brother, S.G.T.’s stepmother, and employees of S.G.T.’s school and DFCS.
- The testimony described repeated emotional and physical abuse and neglect by appellant, including fighting in the child’s presence, dressing S.G.T. in female clothing, and repeated ridicule and humiliation.
- Appellant presented evidence that he tried to obtain help for S.G.T.’s emotional problems and argued the child’s issues were not caused by appellant’s parenting.
- The juvenile court found S.G.T. was a deprived child and terminated appellant’s parental rights as to S.G.T., and appellant appealed, challenging the sufficiency of the evidence.

## Issues

1. Whether the evidence was sufficient to support termination under OCGA § 15-11-51(a)(2) based on a finding, by clear and convincing evidence, that S.G.T. was a deprived child due to appellant’s lack of proper parental care or control and that the deprivation was likely to continue.
2. Whether the evidence was sufficient to support termination under OCGA § 15-11-51(a)(4) for wanton and willful failure to support.

## Decision

- The Court of Appeals of Georgia affirmed the juvenile court’s order terminating appellant’s parental rights as to S.G.T.
- The court held the evidence authorized the juvenile court to find, by clear and convincing evidence, that S.G.T. was deprived due to appellant’s emotional abuse, neglect, and related conduct, and that the deprivation was likely to continue.
- The court rejected appellant’s argument that the record was insufficient to support the deprivation finding.

## Legal Principles

- Parental rights may be terminated under OCGA § 15-11-51(a)(2) when clear and convincing evidence shows the child is deprived because of a parent’s lack of proper parental care or control (including parental misconduct or inability), the causes of deprivation are likely to continue, and continued deprivation is likely to cause serious harm to the child.
- Emotional abuse and humiliation—shown through repeated ridicule, hostile treatment, and degrading conduct—can support a deprivation finding, especially when corroborated by testimony from the child and other witnesses familiar with the home and school environment.
- In reviewing termination orders, an appellate court views the evidence in the light most favorable to the juvenile court’s ruling and asks whether a rational factfinder could have found the statutory grounds by clear and convincing evidence; credibility and weight of testimony are for the juvenile court.
- Evidence of a parent’s conduct demonstrating unwillingness or inability to provide care (including willingness to have a young child jailed and offers to relinquish parental rights) may support findings of deprivation and likelihood of continuation.

## Conclusion

In re S.G.T. affirmed termination of an adoptive father’s parental rights where testimony from the child, family members, school personnel, and DFCS showed a pattern of emotional and physical abuse and neglect, and the record permitted the juvenile court to find by clear and convincing evidence that S.G.T. was a deprived child and that the conditions causing deprivation were likely to continue.


In re S.G.T., 175 Ga. App. 475, 333 S.E.2d 445 (1985)