When conducting a bonding analysis, the court is not required to use expert testimony. In re K.K.R.-S., 958 A.2d 529, 533 (Pa. Super. 2008) (citing In re I.A.C., 897 A.2d 1200, 1208-09 (Pa. Super. 2006)). Social workers and caseworkers can offer evaluations as well.
When conducting a bonding analysis, the court is not required to use expert testimony. In re K.K.R.-S., 958 A.2d 529, 533 (Pa. Super. 2008) (citing In re I.A.C., 897 A.2d 1200, 1208-09 (Pa. Super. 2006)). Social workers and caseworkers can offer evaluations as well.
Furthermore, information by means of expert testimony or bonding evaluations is not required in a trial court's determination of the presence or absence of a bond. See, In re I.A.C., 897 A.2d 1200, 1207-09 (Pa. Super. 2006) (termination of parental rights affirmed based solely on bonding testimony from agency social workers.); In re N.A.M., 33 A.3d 95 (Pa. Super. 2011) (termination of parental rights affirmed over Mother's objection that a formal bonding evaluation was not performed, and bond analysis was based only on testimony by foster care case managers and agency workers).
¶ 20 When conducting a bonding analysis, the court is not required to use expert testimony. In re K.K.R.S., 958 A.2d 529, 533 (Pa.Super. 2008) (citing In re /.AC, 897 A.2d 1200, 1208-09 (Pa.Super .2006)). Social workers and caseworkers can offer evaluations as well.
In analyzing the parent-child bond, the orphans' court is not required by statute or precedent to order a formal bonding evaluation be performed by an expert. See In re I.A.C., 897 A.2d 1200, 1208-1209 (Pa.Super. 2006). ¶ 12 In this matter, the court considered whether a bond existed and found "scant, if any, evidence" that one did. Orphans' Court Opinion at 15.