In re B.R.L., 381 N.C. 56 (2022)

  • Facts: The juvenile was adjudicated neglected. During the first year of the neglect case, mother did not work on her case plan. DSS filed a TPR petition, which was granted. Mother appeals the grounds, arguing the findings do not support the conclusion of neglect based on a likelihood of future neglect.
  • The challenged findings were supported by clear and convincing evidence: therapist testimony. The unchallenged findings support the determination that a likelihood of future neglect existed. Mother was not capable of parenting the child at the time of the TPR hearing and that shows there is a substantial likelihood of future neglect. A parent’s lack of progress on her case plan is indicative of the likelihood of future neglect. mother did not complete many aspects of her case plan addressing DV, substance use, mental health, parenting, and safe housing such that the reasons for the juvenile’s removal remained.
Termination of Parental Rights
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