Domestic Relations – Parent & Child – Reunification Cessation – Termination of Parental Rights – Sufficient Findings

In deciding that DSS could cease its efforts to reunify the respondent-mother and her children, the trial court was not required to recite the language from G.S. § 7B-906(2)(d). Moreover, any deficiency in the findings of the permanency planning order can be cured by findings in the order terminating respondent’s parental rights. In this case, considering the trial court’s findings in both orders – relating to, for example, the difficulty DSS experienced maintaining contact with respondent, respondent’s continued use of methamphetamine, and her other failures to make progress on her case plan – the findings are sufficient under § 7B-906(2)(d).

We affirm the trial court’s elimination of reunification efforts.

In re J.E.H. (Lawyers Weekly No. 012-155-23, 13 pp.) (Fred Gore, J.) Appealed from Stanly County District Court (Thai Vang, J.) Annick Lenoir-Peek for respondent; Valeree Renee Adams for petitioner; Daniel Knight for guardian ad litem. North Carolina Court of Appeals (unpublished)