Supreme Court of North Carolina

In re H.B.

April 28, 2023

Summary

The Court affirmed the termination of respondent’s parental rights, holding that the trial court’s express determination that an evidentiary timeline was credible and reliable converted its reference to that exhibit into a proper evidentiary finding. Those findings supported termination for willful failure to make reasonable progress, and the trial court’s best-interests determination was supported by evidence and was not an abuse of discretion. Any error in permitting amendment of the petition to add another termination ground was harmless because one valid ground independently supported termination.