In re C.J.C., 374 N.C. 42

Child (pseudonym Caleb) born 2014 to unmarried parents; parents separated in 2015 and mother obtained primary physical and legal custody.
2016 district-court order incorporated the parties’ parenting agreement and ordered father to pay $50/week support; a 2017 consent order relieved father of ongoing support and left visitation "as the parties mutually agree."
Mother filed a private petition to terminate respondent-father’s parental rights in October 2018 alleging out-of-wedlock status, failure to provide substantial support/care, and willful abandonment; father denied material allegations.
Trial was held March 21, 2019; on April 4, 2019 the court found grounds (willful abandonment) and that termination was in the child’s best interests, and it terminated the father’s parental rights.
On appeal the father argued (1) the court failed to properly appoint a guardian ad litem (GAL) and the GAL did not perform required duties, and (2) the court abused its discretion at the dispositional stage by failing to make sufficient findings under N.C.G.S. § 7B-1110(a) and by misweighing best‑interest factors (including the mother’s boyfriend/possible adoption).
The Supreme Court affirmed: the omission on the appointment form was a clerical error—the attorney served as GAL and fulfilled GAL duties—and the dispositional findings were sufficient and not an abuse of discretion.

Issue	Petitioner's Argument	Respondent's Argument	Held
Whether the trial court failed to appoint a guardian ad litem as required	Petitioner: the court properly appointed an attorney advocate who acted as GAL and the GAL fulfilled duties	Respondent: the appointment form omitted the GAL designation and the GAL did not offer evidence or explore dispositional options	Held: clerical omission only; record shows the attorney was appointed and performed GAL duties; no prejudicial error
Whether termination was in the child’s best interests under N.C.G.S. § 7B-1110(a)	Petitioner: termination is in child’s best interest given child’s young age, lack of bond with father, need for consistency; adoption likelihood not determinative in private TPR	Respondent: court failed to make findings on relevant factors (mother’s boyfriend, potential future adoption) and misbalanced factors, so termination was arbitrary	Held: court made relevant written findings; factors were considered and balanced; no abuse of discretion; likelihood of adoption less critical in private TPR

In re A.D.L., 169 N.C. App. 701 (2005) (failure to reverse where GAL carried out duties despite missing appointment papers)
In re J.H.K., 365 N.C. 171 (2011) (an attorney GAL may perform both GAL and attorney‑advocate duties)
In re A.R.A., 373 N.C. 190 (2019) (trial court must make written findings only as to relevant best‑interest factors)
In re E.H.P., 372 N.C. 388 (2019) (unchallenged findings are binding on appeal)
Koufman v. Koufman, 330 N.C. 93 (1991) (principle cited for binding effect of unchallenged findings)