In re A.H.G., 284 N.C. App. 297 (2022)

Held: 
Affirmed
  • Facts: In 2020, the juveniles were adjudicated neglected and dependent. In 2021, DSS filed a TPR petition, which was granted. Mother appeals, arguing she made reasonable progress, the findings were unsupported, and the court abused its discretion when determining TPR was in the children’s best interests.
  • G.S. 7B-1110(a) requires the court consider the enumerated factors and make written findings of those that are relevant. One factor is a catchall, “any relevant consideration.” Mother argues the court was required to make findings about the lack of Spanish-language services for mother and the impact of a TPR on the children’s culture. “Assuming language and culture are included in the catchall[,]” the court considered and made findings about those issues.
Category:
Termination of Parental Rights
Stage:
Disposition
Topic:
Best Interests Findings
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