Domestic Relations – Parent & Child – Termination of Parental Rights – Last-Minute Improvements – Sibling Bond

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Although the respondent-parents made some progress on the substance abuse requirements of their case plans, in the months leading up to the termination of parental rights hearing, a friend overdosed in respondents’ home on two different occasions. Under these circumstances, the trial court could find that it was likely that respondents’ past neglect of “Blake” would be repeated if Blake were returned to their care.

We affirm the termination of respondents’ parental rights.

The evidence of the detrimental effect of not having in-person visitation for over a year during the COVID-19 pandemic was uncontested. Consequently, the trial court was not required to make findings of fact on this issue.

The respondent-mother argues the trial court abused its discretion by failing to consider Blake’s bond with his siblings. A juvenile’s relationship with siblings is not a criterion the trial court must consider under G.S. § 7B-1110(a). Nevertheless, the court found that Blake’s therapist indicated that it was in Blake’s best interests to not have contact with his brothers. This was after his brother, “Bryan,” consistently bullied Blake to the point that Blake was fearful to be around his brother without the foster parents present.

Affirmed.

In re B.M. (Lawyers Weekly No. 012-112-23, 26 pp.) (Per Curiam) Appealed from Union County District Court (Erin Hucks, J.) Ashley McBride for petitioner; Kimberly Connor Benton and Anné Wright for respondents; Mary Cavanagh and Jordan Spanner for guardian ad litem. North Carolina Court of Appeals (unpublished)