In re M.S.E., 378 N.C. 40 (2021)

  • Facts: Two juveniles were adjudicated neglected based on circumstances created by mother’s untreated mental health and substance use issues and housing instability. Mother continued to use marijuana and cocaine and did not submit to the majority of required drug screens. She did not comply with recommendations for mental health and substance use treatment. Mother did attend some parenting classes and showed improvements in her interactions with the children. Mother had a psychological assessment that showed she had borderline intellectual functioning and recommended a support person for assistance with parenting, a rep payee, review of written documents with her to ensure she understood. Ultimately, DSS filed a TPR motion, which was granted on the grounds of neglect and failure to make reasonable progress. Mother appeals.
  • The court made sufficient findings under G.S. 7B-1110(a) regarding the disposition and the TPR being in the children’s best interests. The findings were supported by competent evidence. Although mother argues the court erred by not making findings of the dispositional alternatives it considered, G.S. 7B-1110(a) does not require written findings of any dispositional alternatives the court considered.
Termination of Parental Rights
Best Interests Findings
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