In re D.R.J., 381 N.C. 381 (2022)
Held:
Reversed
- Facts: In 2018, the juvenile was adjudicated neglected and placed in DSS custody. Reunification was eliminated as a permanent plan. In 2020, DSS filed a TPR motion alleging failure to pay the reasonable cost of care and dependency as the grounds. The TPR was granted and father appeals.
- G.S. 7B-1111(a)(6) authorizes the court to terminate a parent’s rights when the parent is incapable of providing for proper care and supervision and lacks an appropriate alternative child care arrangement.
- The findings are insufficient to support the conclusion the ground exists. There is one finding related to this ground, which addresses the parent’s inability to provide proper care and supervision. There is no finding about whether there was an appropriate alternative child care arrangement. The findings must address both prongs of the ground. No evidence on the issue of an appropriate alternative child care arrangement introduced at the hearing.
Category:
Termination of Parental RightsStage:
AdjudicationTopic:
Dependency