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Domestic Relations – Parent & Child – Termination of Parental Rights – Appeal & Remand

In re A.B. (Lawyers Weekly No. 011-027-16, 25 pp.) (Donna Stroud, J.) Appealed from Mecklenburg County District Court (Elizabeth Trosch, J.) N.C. App.

Holding: On remand from an order that was self-contradictory, the trial court could properly make findings of fact about the respondent-mother’s progress while ultimately concluding that she had not made sufficient progress to prevent termination of her parental rights.

We affirm the trial court’s order terminating respondent’s parental rights.

Even though the trial court referred to the allegations from the Department of Social Security’s petitions, since the trial court did so in one of 70 findings, it is clear that the trial court made an independent determination of the facts and did more than merely recite DSS’s allegations.


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