California, United States of America
The following excerpt is from Juan C. v. & (In re M.V.), F072590 (Cal. App. 2016):
A court may terminate parental rights of a natural parent when it finds one parent "has left the child in the care and custody of the other parent for a period of one year without any provision for the child's support, or without communication from the parent, with the intent on the part of the parent to abandon the child." ( 7822, subd. (a)(3).) The court considers the frequency of the parent-child communications, the genuineness of the effort and the quality of the communications that occurred. (People v. Ryan (1999) 76 Cal.App.4th 1304, 1316.)
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