The Supreme Court of Pennsylvania has held that child placement agreements voluntarily executed by parents and the county child welfare agency which condition the child's return on the agency's approval are authorized by state statutes and the regulations of the Department of Public Welfare and do not violate the due process clause of the fourteenth amendment to the United States Constitution.
Lee v. Child Care Service Delaware County Institution District, 337 A.2d 586 (Pa. 1975).
David S. Bunnel,
Parent and Child - Custody of Child - Voluntary Relinquishment - Placement Agreements,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol14/iss2/8