In re A.B.C., 374 N.C. 752 (2020)

There is a dissent
as to grounds (4-3)
  • Facts: Mother challenges the findings that her relationship with her child was similar to “playmates” and that the trial court improperly compared her relationship to the child’s relationship with the foster parents.
  • The findings were supported by the evidence. The social worker’s testimony addressed the relationship and interactions between the child and mother when supervising the visits, which showed mother did not take a parenting role but rather played with the child. There was no evidence that supervised visits prevented mother from demonstrating a parental bond.
  • The court did not choose between the parent and foster parent. Mother relies on In re Nesbitt, 147 N.C. App. 349 (2001), which is not binding on the supreme court. Additionally, the findings do not compare the two relationships to determine which was better. Instead, the findings evaluate the bond with mother and quality of relationship with the proposed adoptive placement, and the mention of the foster parents in the finding “serves as a somewhat inartful proxy for describing the quality of the parental relationship.” Sl.Op. at 21.
Termination of Parental Rights
Best Interests Findings
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