In re A.L., 378 N.C. 396 (2021)

Affirmed in Part
  • Facts: Juvenile was adjudicated neglected based on circumstances created by mother’s substance use. Mother had unsuccessfully participated in 3 residential treatment programs, having failed to complete any of them. She sporadically attended outpatient services, admitted to using crack, and tested positive for cocaine. A TPR was initiated based on mother’s willfully leaving child in foster care for 12 months and failing to make reasonable progress to correct the conditions that led to the juvenile’s adjudication or removal. Mother did attend a 4th residential treatment program that she completed. She did not participate in outpatient treatment and had additional case plan requirements she did not complete. The TPR was granted, and mother appeals challenging the determination that she failed to make reasonable progress.
  • Mother’s argument that she consistently sought treatment, relapses are not uncommon, and at the time of the TPR hearing she had been sober and was successfully participating in treatment for 7 months is without merit. The unchallenged findings of mother’s continued substance use and her consistent inability to successfully complete the majority of her inpatient treatment programs along with her failure to maintain sobriety for a meaningful period of time demonstrates extremely limited progress in correcting the conditions leading to the juvenile’s adjudication.


Termination of Parental Rights
Willfully Leaving Child in Foster Care or Other Placement
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