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Supreme Court of Missouri · 2004
In Re KAW, 133 S.W.3d 1 (Mo. 2004)
In reversing and remanding a termination judgment, the court required past parental conduct to be convincingly linked to likely future harm and current conditions. The majority's supporting analysis recognized that needless separation from a familiar parent, especially for very young children, can impair emotional and intellectual development; broader placement-disruption language in the dissent is not treated as the holding.
Some later courts have distinguished or questioned it — read before relying.
Treatment last confirmed August 19, 2026. Case-wide subsequent treatment; human-set. Not specific to any one passage.