Incarcerated Parent Visitation Termination Due to Danger to Child's Best Interests

The appellate court reviewed a lower court's decision to grant a non-custodial parent, who was incarcerated for multiple rapes and sexual offenses and subsequently ordered to be deported, a monthly one-hour visitation right with his young child. The appellate court overturned this decision, reasoning that given the father's severe narcissistic and antisocial personality disorder, lack of remorse, history of extreme violence against victims including the child, the highly inappropriate environment of prison visitation, and the subsequent mandatory deportation which would render any nascent relationship meaningless for the child's formative years, any visitation right would seriously endanger the child's best interests, thus necessitating the complete cessation of personal contact as the ultimate measure under the relevant statutes.