In re A.E.S.H., 380 N.C. 688 (2022)

  • Facts: In 2019, the juvenile was adjudicated neglected based on circumstances involving unsanitary living conditions and father’s substance use and parenting skills. Father was convicted of felony cruelty to animals (the family dog), felony domestic neglect of a disabled or elder person (his wife who ultimately died), and misdemeanor child abuse (the juvenile). Father did not make progress on his case plan, and DSS filed a TPR motion, which was granted. Father appeals.
  • The findings are supported by clear and convincing evidence and support the conclusion of neglect, which includes past neglect and a likelihood of repetition of neglect. A parent’s lack of progress in completing a case plan is an indication of a likelihood of future neglect. Evidence showed the father did not avail himself of parenting classes while he was incarcerated and did not attend parenting classes he was referred to after his incarceration. Father did not follow up with the DSS social worker regarding his parenting classes or a setting up a home visit.
Termination of Parental Rights
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