In re S.Z.H., 247 N.C. App. 254 (2016)

Held: 
Reversed

A termination of parental rights (TPR) hearing consists of two stages: adjudication of a ground, and disposition based on the best interests of the child. To ensure a parent’s constitutional rights to his child are not violated by basing a TPR solely on the child’s best interests, the court must conduct two separate inquiries – adjudication first, then disposition – even when the two stages are held in the same hearing.

Category:
Termination of Parental Rights
Stage:
Hearing
Topic:
Two Stages
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