In a Decision – Div. of Child Protection and Permanency v. P.H. (an Unreported Decision Case) >> the Court Held:
The parent had disciplined the child with a Belt. The Division of Child Protection and Permanency provided that the parent could not discipline the child with a belt. The trial judge found the caseworker's testimony credible and that there was a substantial risk of harm.
The parent admitted hitting daughter with a belt, refused to agree to refrain from doing so and maintained that she would discipline daughter as she chose. Mother refused the mentoring, counseling and other services recommended by the Division. The court thus decided there was a "substantial risk of harm," finding that "there's a parent who has used excessive corporal punishment and intends to continue using it based on her own admission." The Court found the caseworker's testimony credible and that there was a substantial risk of harm.