In re S.D.C.

Summary

The Supreme Court of North Carolina affirmed an order terminating the respondent-father's parental rights in S.D.C. The court held that the trial court was not required to consider or make findings regarding a potential relative placement because the termination hearing record contained no evidence that an available relative placement existed. The court reviewed the best-interests determination for abuse of discretion.

Holdings

1. A trial court may consider the availability of a relative placement as a relevant consideration under N.C.G.S. § 7B-1110(a)(6), but it is not required to consider or make findings about that issue when the termination-hearing record contains no evidence tending to show that a potential relative placement is actually available.
2. The trial court did not abuse its discretion in determining that termination of respondent-father's parental rights was in Sam's best interests.

Questions Presented

1. Whether the trial court abused its discretion during the dispositional phase of the termination proceeding by failing to consider and make findings concerning the possible placement of the juvenile with his paternal grandmother.
2. Whether the trial court's determination that termination of respondent-father's parental rights was in the juvenile's best interests should be affirmed.

Disposition

affirmed