The possibility that a child may suffer serious psychological or emotional harm from severing bonds with foster parents is not alone sufficient grounds for termination of parental rights, a New Jersey appeals court says.

What must be proved, in essence, is that formation of foster-parental bond was in large part the birth parent’s doing, to the point where “any harm caused to the child by severing the bond rests at the feet of the parent,” the Appellate Division held in Division of Youth and Family Services v. D.M., A-6020-08.