In re N.G., 374 N.C. 891 (2020)

  • Facts: In 2107, the juvenile was adjudicated dependent. Ultimately DSS filed a petition to TPR, which was granted on multiple grounds. Respondent mother appealed the best interests determination (father appealed the grounds, which is discussed above).
  • At the dispositional stage of a TPR, the court determines whether the TPR is in the child’s best interests based on the factors listed in G.S. 7B-1110(a). The trial court properly considered the factors and made findings of fact. The challenged findings were supported by the evidence, which included the social worker’s testimony and the GAL report.
  • Although a stated purpose of the Juvenile Code is to prevent the unnecessary or inappropriate separation of children from their parents, the child’s best interests are the court’s paramount consideration, and when it is not in the child’s best interests to return home, the child should be placed in an safe, permanent home within a reasonable amount of time. G.S. 7B-100. Here, the child had been in the foster home for almost 2 years without being any closer to reunifying with her parents, and the foster parents were meeting her needs and wanted to adopt her and provider her with a permanent home.
Termination of Parental Rights
Best Interests Findings
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