Matter of Michael J.L.

Holding The Appellate Division affirmed the termination of the father’s parental rights on the ground of permanent neglect, finding that the petitioner met its burden of showing diligent efforts while the father failed to plan for the child’s future. The court also rejected the father’s due process and bias claims, noting the bias argument was unpreserved.

The court’s words

petitioner met its burden of establishing by clear and convincing evidence that it exercised diligent efforts to encourage and strengthen the parent-child relationship

2026 NY Slip Op 04670, at the official text

the father failed to plan for the child's future

2026 NY Slip Op 04670, at the official text

the father failed to obtain suitable housing and failed to make adequate progress in the parenting and mental health services

2026 NY Slip Op 04670, at the official text

the record supports the court's determination that termination of [his] parental rights is in the best interests of the child

2026 NY Slip Op 04670, at the official text

that contention is unpreserved for our review inasmuch as he did not file a motion for the court to recuse

2026 NY Slip Op 04670, at the official text