In re Baby Boy, 238 N.C. App. 316 (2014)


  • Facts and procedural history: Mother executed relinquishment of her newborn with an adoption agency. The agency placed the child with appellee parents, who petitioned for adoption. Mother challenged the validity of her relinquishment, and the district court determined the relinquishment void and dismissed the adoption petition. Appellee parents and the adoption agency appealed the district court order, and the COA reversed. See In re Adoption Baby Boy (April 15, 2014). Pending that appeal, appellee parents filed for termination of the mother’s parental rights, which was granted.  Respondent mother appeals the TPR.
  • Although mother’s relinquishment was determined to be valid, the appeal of the TPR was not moot because of future collateral legal consequences for the mother. Specifically, G.S. 7B-1111(a)(9) makes the involuntary termination of parental rights combined with a parent’s inability or unwillingness to establish a safe home a ground for terminating her rights to any other child she has or may have.


Termination of Parental Rights
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