In re D.C., 236 N.C. App. 287

DSS filed a juvenile petition in 2011 alleging Derrick as neglected and dependent; adjudication followed in 2011.
18 Apr 2012 order changed Derrick’s permanent plan to adoption and directed filing of a termination petition.
24 Jan 2013 order terminated respondent-mother’s parental rights for neglect, failure to progress, and support issues.
Respondent-mother preserved her right to appeal the 2012 permanency planning order; DSS argued no cessation order was made.
This Court previously reversed/remanded, and the NC Supreme Court remanded for reconsideration under In re L.M.T.; court now affirms after reconsideration.
Finding: combined review of the Permanency Planning Order and the TPR Order shows the statutory findings were satisfied when viewed together

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Permanency Planning Order alone satisfied 7B-507(b)(1).	Mother argues the order ceased reunification without required findings.	DSS contends no cessation order was made independently.	Permanency Planning Order alone deficient.
Whether the TPR Order together with the Permanency Planning Order satisfied 7B-507(b)(1).	Mother contends combined findings were still insufficient.	DSS argues combined orders satisfy statutory requirements.	When read together, the orders meet the statutory findings.
Whether termination of parental rights was in Derrick’s best interests.	Mother challenges the best-interests analysis.	DSS argues statutory best-interest criteria supported termination.	Court did not abuse discretion; termination in Derrick’s best interests.

In re L.M.T., 752 S.E.2d 453 (N.C. 2013) (reconsideration under 7B-507(b) guidance; cease reunification can be satisfied by combined orders)
In re D.C., 752 S.E.2d 257 (N.C. App. 2013) (unpublished; related discussion of findings and reunification cessation)