03-04-09 DYFS v. A.R. - I/M/O Guardianship of C.S., Jr.
A-5079-07T4
A comparative bonding evaluation of the child with his or
her natural parents and foster parents is almost always
necessary even when DYFS satisfies the second prong of the "best
interests" test for termination of parental rights, and was
necessary in this case. We affirm the denial of termination on
DYFS' appeal as to the youngest child only where the Family Part
denied termination as to the mother of all four children. (The
fathers had been terminated and do not appeal). If
reunification is unduly delayed, the Family Part can appoint a
professional to oversee the reunification process.
