Voluntarily Placing Child in Foster Care Due to Parents Mental Illnesses
In In re Guardianship of R.G. and F., 155 N.J. Super. 186, 194-95, 382 A.2d 654 (App.Div.1977) three children were voluntarily placed in foster care and when the parents demanded their return, the Division refused. Counseling and therapy were initially refused by the parents.
The parents later agreed to a counseling program and the children were temporarily returned. the father subsequently requested that the children be placed in foster care due to stresses operating within the family and the children were again removed by the Division. the trial judge entered an interim order for mental evaluations of the parents. the medical testimony at the hearing disclosed that the father suffered from severe paranoid schizophrenia while the mother was diagnosed as a passive-dependent inadequate personality.
The experts believed that as a result of the parents' mental impairments the children would be at risk.
No physical abuse or neglect was asserted, but the parents' mental illnesses created an environment in which they were unable to adequately care for and raise the children. Id. at 194, 382 A.2d 654.
As in this case, neither of the parents were morally culpable or blameworthy; it was their mental disabilities which rendered them unable to parent. In R.G. and F., Judge King stated: "The fact that the parents may be morally blameless in this unfortunate situation is not conclusive on the issue of permanent custody. Undoubtedly, their inadequacy as parents stems from their mental illness . . . N.J.S.A. 30:4C-15(c) speaks to the 'best interests of any child,' not the presence or absence of culpable fault on the parents' part." Id. at 194-95, 382 A.2d 654.