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


A TPR order shall be entered no later than 30 days after the completion of the hearing. If the order is not timely entered, the clerk shall schedule a subsequent hearing at the first session of court scheduled for juvenile mattes after the 30 day period expires so that there may be an explanation as to the delay and the ability to obtain needed clarification for the order. The order should be entered within 10 days of this subsequent hearing. G.S. 7B-1109(e), -1110(a).  In this case the court violated the time period when the hearing concluded on January 26, 2015 but did not enter the TPR order until July 23, 2015. A party may petition for a writ of mandamus when this time period is not met. “In almost all cases, delay is directly contrary to the best interests of the children, which is the ‘polar star’ of the North Carolina Juvenile Code.“

Termination of Parental Rights
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