In re A.M., 377 N.C. 220 (2021)

  • Facts: In 2017, the children were adjudicated neglected. The parents were ordered to comply with a case plan to address issues involving substance use, housing, income, domestic violence, mental health, and criminal activity. DSS filed a motion to terminate the parents’ rights. The TPR hearing was held in 2020, and the parents’ rights were terminated. Mother appeals, challenging the grounds and best interests. She argues the court disregarded the finding about the bond between her and the child.
  • G.S. 7B-1110(a) set forth the criteria the court must consider at the dispositional phase when addressing whether the TPR is in the best interests of the juvenile. Written findings are required for those factors that are relevant.
  • The trial court made findings of fact for each of the six factors. Mother does not challenge the findings but rather the weight given to the bond between the parent and child. The trial court determines how much weight to give the factors. The court weighed the evidence, recognized the parent-child bond, but gave greater weight to the other factors listed in G.S. 7B-1110(a) and concluded the TPR would be in the juveniles’ best interests. The court did not abuse its discretion in weighing the factors.
Termination of Parental Rights
Best Interests Findings
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