In re S.C.C., 379 N.C. 303 (2021)

  • Facts: In 2018, the juvenile was adjudicated neglected and was placed in DSS custody. In two separate 2019 permanency planning orders, the court found the parents were subject to child support orders and at most the parents made a single payment. When the primary permanent plan was identified as adoption, DSS filed a TPR motion. The TPR was granted, and both parents appeal the grounds and disposition. The summary focuses on the disposition.
  • At disposition, the court considers the factors at G.S. 7B-1110(a). The standard of review is whether there is evidence to support the findings and whether the court committed an abuse of discretion. Unchallenged findings are binding.
  • The unchallenged findings show the juvenile was in foster care for 28 months, the parents did not exercise their visitation rights and failed to complete their case plans, and support the finding that there was no reasonable probability of reunification within a reasonable period of time. These findings are not based on the parents’ poverty. Other challenged findings regarding the lack of bond between the parents and child are supported by competent evidence: social worker testimony and the GAL report. There is no abuse of discretion.
Termination of Parental Rights
Best Interests Findings
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