In re C.S., 380 N.C. 709 (2022)

  • Facts: Father appeals TPR, arguing in part that the court erred in determining it was in the child’s best interests by not making findings about the parent-child bond as required by G.S. 7B-1110(a)(4).
  • The court explicitly found that the father loves his child, which demonstrates the court considered the parent-child bond. The court further found that father is not in a position to provide his child with a stable, safe, and nurturing environment and the child has a strong bond with his foster parents. As previously held, the parent-child bond factor is properly addressed by findings “that any previous bond or relationship with the [respondent parent i]s outweighed by [the child’s] need for permanence.” 380 N.C. at 715 (citation omitted). There as no abuse of discretion.
Termination of Parental Rights
Best Interests Findings
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