In re A.L.L., ___ N.C. App. ___, 802 S.E.2d 598 (2017)

Held: 
Affirmed
  • Clear, cogent, and convincing evidence supported the court’s findings and conclusion of dependency. A mental health evaluation conducted a year before the TPR hearing can support a TPR where the “persistence of her personality problems” characterized in the evaluation is “not easily amenable to change” and there is a lack of mental health treatment. In this case, a 2 year old and then 1 year old evaluation that showed the respondent (1) had recurring severe depression and PTSD, which are longstanding mental health conditions, and (2) failed to follow through with treatment recommendations  necessary to care for her children safely constitute clear and convincing evidence.
Category:
Termination of Parental Rights
Stage:
Adjudication
Topic:
Dependency
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