In re L.G.G., 379 N.C. 258 (2021)

  • Facts: The children were adjudicated neglected. Once in care, the children started showing sexualized behaviors and made disclosures, which the parents did not believe. The children’s behaviors started regressing after visits. Reunification efforts and reunification were eliminated, and adoption was identified as the primary plan. DSS filed a TPR motion. The TPR was granted, and respondents’ appeal the adjudication; father also appeals the best interests determination regarding the oldest child.
  • G.S. 7B-1110(a) requires the court to consider the enumerated facts and make written findings on only those factors that are relevant.
  • Although the older child had significant behavior issues and he was not in a position to be adopted at the time of the TPR hearing, testimony of his progress in treatment and possibility of finding a long-term adoptive or foster home supports the court’s conclusion that adoption was a realistic possibility as he continues to improve in the next year or two. The lack of an adoptive placement at the time of at the TPR hearing is not a bar to TPR.
  • The trial court weighed the dispositional factors and did not abuse its discretion.


Termination of Parental Rights
Best Interests Findings
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