In re L.L.O., 252 N.C. App. 447 (2017)

Vacated and Remanded
  • When the child has not been in the parent’s custody for a significant period of time before the TPR hearing and the ground is neglect, the trial court must consider the history of neglect and the probability of a repetition of neglect.
  • The child was adjudicated neglected based the failure of her parents to provide necessary medical and remedial care. The court’s findings that address the parents’ lack of employment, failure to provide financial assistance to the child, missed and failed drug screens, irregular contact with the child, and insufficient housing do not “address or mention the probability of repetition of neglect or failure to provide necessary medical or remedial treatment to” the child. An order that lacks the required finding of fact that the parent was likely to repeat the neglect does not establish the ground for termination and is not harmless error. 
Termination of Parental Rights
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