In re C.S.

Summary

The Supreme Court of North Carolina affirmed an order terminating the respondent father's parental rights to C.S. based on neglect under N.C.G.S. § 7B-1111(a)(1). The court held that the prior neglect adjudication supported a finding of past neglect and that the trial court properly determined both a likelihood of future neglect and that termination was in the child's best interests.

Holdings

1. The trial court did not err in finding past neglect and adjudicating neglect as a ground for termination. Evidence of neglect by a parent before loss of custody, including a prior adjudication of neglect, is admissible in a subsequent termination proceeding, and the parent whose rights are being terminated need not have been responsible for the prior adjudication.
2. The trial court did not abuse its discretion in determining that termination of respondent's parental rights was in C.S.'s best interests.

Questions Presented

1. Whether the trial court erred in determining that neglect constituted a ground for termination of respondent's parental rights under N.C.G.S. § 7B-1111(a)(1), including whether there was evidence of past neglect and a likelihood of future neglect.
2. Whether the trial court abused its discretion in determining that termination of respondent's parental rights was in the juvenile's best interests, including whether it adequately considered the bond between respondent and the juvenile under N.C.G.S. § 7B-1110(a)(4).

Disposition

affirmed