In re N.P., 374 N.C. 61

Pitt County DSS obtained custody of N.P. ("Nick") in Sept. 2016 after he tested positive for cocaine at birth; Nick was adjudicated neglected and dependent in Feb. 2017.
DSS petitioned to terminate parental rights of both parents in Nov. 2018, alleging neglect, more-than-12-months nonprogress, failure to pay for care, and dependency.
Respondent father has 2001 convictions on multiple sex-offense counts against a child, denied responsibility, and had not completed sex-offender-specific treatment; he demonstrated paranoia and erratic behavior in evaluations and therapy.
The district court found repeated housing instability, poor roommate choices (including potential exposure to a registered sex offender), dishonesty about housing, and conduct indicating ongoing mental-health issues that would put Nick in an injurious environment.
On 13 March 2019 the district court concluded grounds existed to terminate the father’s parental rights (including neglect under N.C.G.S. § 7B-1111(a)(1)) and separately found termination was in Nick’s best interests; the father appealed only the adjudication findings.

Issue	DSS (Plaintiff) Argument	Father (Defendant) Argument	Held
Whether grounds existed to terminate parental rights for neglect under § 7B-1111(a)(1)	Past neglect plus evidence (criminal history, untreated sex-offender issues, mental-health problems, housing instability) shows a high probability of future neglect	Findings unsupported by the record; father claims he alleviated conditions that led to removal	Affirmed: findings supported by clear, cogent, convincing evidence; court expressly found high probability of future neglect
Whether the court erred by relying on past events (housing instability) rather than father’s status at hearing	Past conduct and recent behavior may be reasonably inferred to show ongoing risk; court may consider changed circumstances	Father asserts housing issues were historical and corrected by hearing date	Affirmed: court reasonably inferred ongoing instability and lack of ability to maintain safe housing; findings supported
Whether court made a specific finding on probability of repetition of neglect	Court made an explicit ultimate finding that repetition was highly probable	Father contends court failed to make the required explicit finding	Affirmed: court expressly found a high probability of repetition
Whether termination was in the child’s best interests	Termination served child’s best interests (district court found so)	Father did not challenge the best-interests determination on appeal	Affirmed (unchallenged on appeal)

In re Montgomery, 311 N.C. 101, 316 S.E.2d 246 (establishing adjudicatory/dispositional stages and review standard)
In re D.L.W., 368 N.C. 835, 788 S.E.2d 162 (addressing need to show past neglect and likelihood of future neglect)
In re Ballard, 311 N.C. 708, 319 S.E.2d 227 (explaining consideration of past neglect and future risk when child long separated)
In re Z.V.A., 373 N.C. 207, 835 S.E.2d 425 (requiring the district court to consider changed circumstances when evaluating future neglect)
In re T.N.H., 372 N.C. 403, 831 S.E.2d 54 (unchallenged findings are binding and only necessary findings are reviewed on appeal)
In re Moore, 306 N.C. 394, 293 S.E.2d 127 (standard for appellate review of trial court findings)