In re J.J.H., 376 N.C. 161 (2020)

  • Facts: The juveniles were adjudicated neglected in an underlying juvenile action. After the primary permanent plan was changed to adoption, DSS filed a motion to TPR, which was granted on the ground of neglect. Mother appeals the ground and the disposition to TPR.
  • Standard of review for the dispositional stage regarding best interests is whether the trial court abused its discretion. Dispositional findings must be supported by competent evidence.
  • At a TPR disposition, “the trial court must determine the best interests of each child based upon his or her individual circumstances.” 41. Here, the court made findings with respect to each child and weighed those findings when determining whether TPR was in the best interests of each juvenile. The court considered the bonds of each child with her as well as with each other. Although some of the children were not in a pre-adoptive placement, the absence of such a placement does not bar a TPR.
  • There as no abuse of discretion.
Termination of Parental Rights
Best Interests Findings
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