State ex rel. Wallace v. Lhotan

In State ex rel. Wallace v. Lhotan (51 AD2d 252, 255 [2d Dept 1976], lv denied 39 NY2d 705, appeal dismissed 39 NY2d 743), the appellate court observed that the foster parent had "a duty not to interpose herself between the children and their natural mother," and that her alienating behavior warranted court intervention. The Lhotan Court explained: "In any case, the foster parents must make a serious attempt to encourage, not discourage, the improvement of relations between the children under their charge and a mother who is trying to re-establish the bonds of family love and concern. A portion of the love that foster parents have for the children must be directed towards easing their return to their natural parent. Whatever circumstances will rend the family fabric, it should not be the result of actions of the foster parents, who have taken on their delicate responsibilities on the solemn promise to do otherwise." (Id., at 259.)