In re J.R.F., 380 N.C. 43 (2022)

  • Facts: In 2018, the juvenile was adjudicated neglected based on circumstances involving parent’s substance use, domestic violence, mental health issues, parenting deficits, and housing instability. In 2020, DSS filed a TPR petition, which was granted. Father appeals, challenging the grounds and best interests determination.
  • The best interests determination is reviewed for an abuse of discretion. The court considers the factors at G.S. 7B-1110(a) and makes written findings of those that are relevant. There was no abuse of discretion.
  • The court acted within its authority, when assessing all the evidence it inferred that the child’s bond with his father had diminished during the 2 years the child was in DSS custody. The court recognized the parent-child bond, but that bond is just one factor the court considers. The court may give greater weight to other factors. The evidence also supports the court’s finding of the child’s likelihood of adoption.
Termination of Parental Rights
Best Interests Findings
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