In re M.K.

Summary

The Supreme Court of North Carolina affirmed the termination of respondent-mother’s parental rights based on neglect. Although it disregarded several unsupported portions of the trial court’s findings, the remaining findings established past neglect and a high likelihood that neglect would recur because respondent-mother had not adequately addressed her mental-health, housing, domestic-violence, substance-use, and parenting problems. The court held that domestic-violence evidence was relevant to the future-neglect inquiry even if it had not independently formed the basis of the original neglect adjudication.