In re C.J.H., 240 N.C. App. 489 (2015)


  • The ground of willful abandonment does not require a continuous absence of the parent for the six requisite months prior to the filing of the petition or motion. Willfulness is a question of fact for the court, and the court’s findings that the father made untimely and inconsistent child support payments, had no contact with the child, and lacked a good faith effort to maintain or re-establish a relationship supports the court’s conclusion of abandonment.
  • Although the relevant time period for abandonment is the six months immediately preceding the filing of the petition or the motion, the court may look at the respondent’s conduct prior to that period when evaluating the respondent’s credibility and intention regarding good faith efforts to maintain a parental relationship with the child via contact and support. Last minute efforts not made in good faith will not negate a court’s’ conclusion of abandonment.


Termination of Parental Rights
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