In re T.H., 232 N.C. App.16 (2014)

• Adoption severs all parental rights of a biological parent such that the biological parent does not have a right to intervene in a juvenile proceeding for the adopted child or have standing to appeal an adjudication or disposition order for that child.
• In a juvenile proceeding, permissive intervention allows the intervenor to provide full and accurate information regarding the child’s welfare, but this purpose can be accomplished through the indirect participation of that individual as a witness or suggested relative placement rather than through intervenor status.*
• Facts: This case involves six juveniles; four of whom had been adopted by their maternal grandmother in 2009 and two of whom were placed in the custody of their maternal grandmother.  After their maternal grandmother was murdered, all six juveniles were adjudicated dependent in 2012, and DSS was granted legal custody and placement authority for all the juveniles. Respondent mother of the two juveniles who were not adopted filed a motion to intervene as of right as the children’s sister (her mother had adopted her four biological children).  Her motion was denied, and she appealed. 

*  Prior to S.L. 2013-129, G.S. Chapter 7B, Subchapter 1 (Abuse, Neglect and Dependency) only addressed intervention under the termination of parental rights statute, therefore, allowing the court to look to Rule 24 of the North Carolina Rules of Civil Procedure in an A/N/D action.  As of October 1, 2013, G.S. 7B-401.1(h) addresses intervention in an abuse, neglect, and dependency proceeding and limits who may intervene. S.L. 2015-136 created G.S. 7B-401.1(e1) addressing intervention by a foster parent.