In re I.G.C., 835 S.E.2d 432

DSS removed two children (Ivy and Jacob) after reports that mother drank and used methamphetamine, drove intoxicated with the children, and had a vehicle incident; father reportedly used alcohol and illegal drugs.
On 4 Nov 2016 the juveniles were adjudicated dependent; parents were placed on case plans addressing substance abuse, mental health, domestic violence, housing, and employment.
By 23 Oct 2017 the court found only minimal progress, set adoption as the permanency plan, and ordered DSS to seek termination of parental rights.
DSS filed termination motions (grounds included neglect, failure to make reasonable progress under N.C.G.S. § 7B-1111(a)(2), and abandonment); the termination hearing occurred 25–26 Sept 2018.
The district court terminated both parents’ rights on 2 Jan 2019, concluding findings supported termination and it was in the children’s best interests; parents appealed.
The Supreme Court of North Carolina affirmed, finding the district court’s findings supported by clear, cogent, and convincing evidence and that termination was warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mother’s rights could be terminated under § 7B-1111(a)(2) for failure to make reasonable progress	DSS: mother made only minimal progress and failed to complete recommended treatment and stabilizing tasks within the relevant period	Mother: she had made significant progress by hearing time (employment, housing, treatment participation) and findings were insufficient	Court: affirmed termination under (a)(2); findings show minimal progress until reunification efforts ceased and insufficient completion of core treatments
Whether district court made sufficient findings to support termination generally	DSS: record contained clear, cogent, convincing evidence and adequate findings	Mother: findings failed to fairly credit her progress	Court: findings were adequate, considered progress, and supported legal conclusions
Whether father’s appeal has merit (no-merit brief)	DSS: district court orders supported by competent evidence	Father (via counsel): no meritorious issues; father declined to file pro se arguments	Court: independent review agreed with counsel; affirmed termination

In re Montgomery, 311 N.C. 101 (1984) (standard for appellate review: findings must be supported by clear, cogent, and convincing evidence)
In re Moore, 306 N.C. 394 (1982) (appellate review principles in termination proceedings)
In re D.L.W., 368 N.C. 835 (2016) (dispositional stage requires inquiry into juvenile's best interests)
In re Young, 346 N.C. 244 (1997) (dispositional best-interests inquiry following adjudication)
In re T.N.H., 831 S.E.2d 54 (N.C. 2019) (termination under § 7B-1111(a)(2) may alone support termination)
In re L.E.M., 831 S.E.2d 341 (N.C. 2019) (procedures for reviewing no-merit briefs in appeals of termination orders)