authority to terminate parental rights. Undisputed evidence that a parent has failed to establish normal relations with his or her child will be sufficient to make out a presumptive case to terminate parental rights. Courts are cognizant that although incarceration does not in and of itself establish a basis for termination of parental rights, they place great emphasis on evidence that the parent-child relationship may have deteriorated sufficiently to make reunification an unrealistic goal.
Numerous obstacles can hinder an effective parent-child relationship when a parent is incarcerated: distance of the prison facility; restrictive visiting hours; lack of cooperation by prison authorities; and communication and transportation problems (Beckerman, 1994; Hairston, 1991). The more severely the relationship is strained, the greater the possibility that a judge will be prompted to terminate parental rights. Conditions for children of incarcerated persons will improve only when there is an increased understanding that children of incarcerated parents are "sentenced" along with the parents.