In re H.B., 285 N.C. App. 1 (2022)

There is a dissent
by Woods, J.
  • Facts: In 2019, the juveniles were adjudicated neglected and dependent due to circumstances created by mother’s substance use, mental health, housing, and lack of appropriate supervision. The juveniles were placed in DSS custody. In 2020, mother’s parental rights to one of the juveniles was terminated. In 2021, DSS filed a TPR petition to terminate mother’s parental rights of H.B. The TPR was granted and mother appeals both the grounds and disposition.
  • A disposition is reviewed for an abuse of discretion. The trial court considers all the factors enumerated in G.S. 7B-1110(a) and must make written findings of those that are relevant. A factor is relevant when there is conflicting evidence on that factor.
  • The parent-child bond is not a dispositive factor at disposition. The court did not abuse its discretion when considering all the factors in G.S. 7B-1110(a). The court found there was no parent-child bond, which mother challenges.
  • Dissent: there is no evidence to support the finding to show no parent-child bond.
Termination of Parental Rights
Best Interests Findings
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