In re Hans S.
Parents Jack and Ursula S. appealed a Family Court order from Rockland County dated July 6, 1979, which declared their son, Hans S., permanently neglected and authorized his adoption. The Rockland County Department of Social Services had intervened in 1975 due to neglect reports, leading to Hans being placed in foster care in 1976. The agency later petitioned for permanent neglect, alleging parental failure to plan for Hans's return and refusal of mental health services. The appellate court reversed the order and dismissed the petition, finding insufficient evidence that the parents failed to plan for their child's future, citing their engagement in psychiatric counseling and consistent visits with Hans. The court concluded that the agency's proof of "lack of planning" was inadequate.