In re J.H., 837 S.E.2d 847

Mother of nine with long history of CPS involvement; four older children previously relinquished; over 40 CPS reports across 20 years.
In Oct–Nov 2016 DSS received reports that mother physically disciplined two sons and that daughter Zendaya was sexually abused by an older son (I.H.) after mother moved into his home despite prior warnings about his danger.
Jared (then 9), Zendaya (4), Aaron, and Devon were removed from mother’s custody on November 11, 2016 and adjudicated abused/neglected on April 3, 2017.
Court-ordered reunification tasks included mental health assessment, six months’ employment and stable housing, parent coaching, and release forms; mother partially complied but struggled with parenting skills and employment.
On February 26, 2018 the trial court ceased reunification efforts and limited visitation; DSS filed petitions to terminate parental rights; on February 6, 2019 the court terminated mother’s parental rights to the four children, finding statutory grounds and that termination was in the children’s best interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by ceasing reunification and excluding mother as a permanent plan	DSS: mother made only some progress, failed to comply with employment requirement, parenting coach documented unsafe parenting and recommended ending coaching; return would be contrary to children’s welfare	Mother: she complied with parts of the plan and made progress; findings of only "some progress" unsupported	Affirmed — findings supported by competent evidence; no abuse of discretion in ceasing reunification
Whether termination of parental rights was proper at the dispositional stage (best interests)	DSS: children are thriving in placements, each has a high likelihood of adoption, return risks repeated abuse/neglect, termination advances permanent plan	Mother: termination based improperly on adoption prospects and children’s special needs; argued dispositional decision unjustified	Affirmed — trial court made required statutory findings, considered bonds/adoptability, and did not abuse its discretion in finding termination in children’s best interests

In re L.M.T., 367 N.C. 165 (N.C. 2013) (trial court findings conclusive if supported by competent evidence; permanency findings need not quote statute)
In re N.G., 186 N.C. App. 1 (N.C. Ct. App. 2007) (review standards for cessation of reunification and disposition; best-interests focus at disposition)
In re Montgomery, 311 N.C. 101 (N.C. 1984) (termination involves separate adjudicatory and dispositional stages)
In re D.L.W., 368 N.C. 835 (N.C. 2016) (dispositional-stage termination reviewed for abuse of discretion)
In re T.L.H., 368 N.C. 101 (N.C. 2015) (articulation of abuse-of-discretion standard)
State v. Hennis, 323 N.C. 279 (N.C. 1988) (abuse of discretion occurs when a ruling is manifestly unsupported by reason)