need for a strong and healthy family relationship”); see also Weintraub v. Brown, 98 A.D.2d 339, 470 N.Y.S.2d 634, 641 (1983) (“We are loath to adopt a rule, the primary effect of which is to encourage, indeed reward, the parents’ disparagement or outright denial of the value of their child’s life.”). Finally, because the amount of emotional distress experienced as a result of unintended parenthood would vary greatly among different individuals, mental-anguish damages in wrongful pregnancy cases have been characterized as too speculative to be recoverable. See, e.g., Crawford, 929 S.W.2d at 637 (denying as speculative parents’ claim for emotional suffering against physician who negligently performed sterilization procedure); cf. Jacobs v. Theimer, 519 S.W.2d 846, 849 (Tex. 1975) (<HOLDING>); but see Flax, 896 S.W.2d at 841, 843-45
holding that in order to support a termination of parental rights based on prospective abuse it is necessary to show that the behavior of the parent was beyond the parents control likely to continue and placed the child at risk and citing as an example the parents mental illness recognizing policy and ruling that person who failed to file counterclaim when childs paternity was being determined in earlier litigation should not be allowed to bring later suit to establish that he was childs natural father as this would not be in the childs best interests holding that parents who sued doctor for negligent failure to diagnose childs affliction in utero could not recover mentalanguish damages because such award would be based upon speculation as to the quality of life and as to the pluses and minuses of parental mind and emotion holding that courts may look to parental conduct both before and after childs birth to determine whether termination is appropriate that parents conduct need not be directed at child and that danger to childs wellbeing may be inferred from parental misconduct standing alone holding that the emotional benefits to the parents resulting from the childs birth could be applied to offset any damage award