In re J.A.M., 375 N.C. 325 (2020)

Held: 
Affirmed
  • Facts: This appeal of a TPR has a lengthy procedural history including an underlying juvenile action and prior appeals. This appeal is made pursuant to Appellate Rule 3.1(e), where respondent mother’s counsel filed a no merit brief, and respondent mother filed a brief raising several issues. This summary focuses on one issue  - recusal and family court districts.
  • Although mother raised judicial bias, there was none. The practice of “one judge, one family” is recognized in North Carolina and “reflects a central policy of the state.”  Sl. Op. at 10, 11. A judge is not required to recuse themselves in a TPR when they have presided over earlier permanency planning hearings and ordered adoption as the primary permanent plan.
Category:
Termination of Parental Rights
Stage:
Hearing
Topic:
Recusal
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