In re C.J.

Summary

The Supreme Court of North Carolina affirmed an order terminating the respondent-mother’s parental rights to her daughter. The Court held that the evidence supported termination under N.C.G.S. § 7B-1111(a)(2), based on the mother’s willful failure to make reasonable progress while the child remained in foster care, and declined to address the remaining grounds because that ground independently supported termination.

Holdings

1. The Court need not review challenged findings that are unnecessary to support the trial court's conclusion that grounds existed to terminate respondent-mother's parental rights.
2. A termination conclusion under N.C.G.S. § 7B-1111(a)(2) is supported when there is a nexus between the components of the court-approved case plan with which the parent failed to comply and the conditions that led to the child's removal.
3. The trial court's findings were supported by clear, cogent, and convincing evidence and fully supported termination under N.C.G.S. § 7B-1111(a)(2) because respondent-mother willfully left the child in foster care for more than twelve months without making reasonable progress to correct the conditions leading to removal.
4. The ground under N.C.G.S. § 7B-1111(a)(2) was sufficient by itself to support termination, so the Court did not need to address respondent-mother's challenges to the remaining grounds.

Questions Presented

1. Whether challenged findings of fact were unsupported by clear, cogent, and convincing evidence.
2. Whether the trial court properly concluded under N.C.G.S. § 7B-1111(a)(2) that respondent-mother willfully left the child in foster care for more than twelve months without making reasonable progress to correct the conditions that led to removal.
3. Whether the remaining grounds for termination and the best-interests determination required appellate review after one statutory ground was properly established.

Disposition

affirmed