In re R.L.D., 375 N.C. 838

Juvenile ("Robin") born 2006; respondent-mother had a history of drug use, unstable housing, domestic violence in the child’s household, and an investigation after Robin’s leg was broken in 2007.
From 2009–2012 Robin lived with paternal relatives (R.D., G.D.) after respondent-mother relinquished primary care; in 2012 respondent-mother executed documents granting custody/medical authorization to R.D. and G.D.
In 2014 R.D. and G.D. relocated with Robin to North Carolina; petitioners (cousins-in-law) provided continued care and, in June 2015, respondent-mother signed an agreement granting petitioners guardianship. Robin has lived with petitioners since 2015.
Petitioners filed to terminate parental rights (March 2019), alleging neglect, dependency, and willful abandonment. The trial court entered findings in December 2019 that respondent-mother had no stable housing or employment, provided no financial support since 2012, had sporadic and sometimes inappropriate contact, and had not remedied conditions that led to loss of custody.
The trial court terminated respondent-mother’s parental rights under N.C.G.S. § 7B-1111(a)(1), (6), (7) and concluded termination was in the child’s best interest; respondent-mother appealed, challenging the adjudicatory findings.
The Supreme Court of North Carolina affirmed, holding the trial court’s unchallenged findings supported termination on the neglect ground alone and that one statutory ground was sufficient to support termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether grounds existed to terminate parental rights under N.C.G.S. § 7B-1111(a)(1) (neglect)	Petitioners: the evidence and findings show past injurious environment, continued risk, lack of contact/support, unstable housing/employment — likelihood of future neglect.	Respondent-mother: trial court’s findings do not establish neglect or a likelihood of future neglect.	Affirmed: trial court’s findings (unchallenged) supported a finding of likely future neglect and termination under § 7B-1111(a)(1).
Whether the trial court’s factual findings were supported by clear, cogent, and convincing evidence	Petitioners: testimony and documentary agreements establish abandonment of care, lack of support, and instability.	Respondent-mother: challenges sufficiency of findings on housing/employment and neglect.	Affirmed: testimonial evidence supported findings of unstable housing/employment and other facts; unchallenged findings are binding on appeal.
Whether the Court needed to address other statutory grounds or best-interest finding	Petitioners: one proven ground (neglect) is sufficient; best-interest not contested.	Respondent-mother: sought reversal of adjudication generally.	Affirmed: under In re E.H.P. one statutory ground suffices; best-interest determination was not challenged, so termination stands.

In re Z.A.M., 374 N.C. 88 (2020) (juvenile code two-step termination framework).
In re A.U.D., 373 N.C. 3 (2019) (burden: clear, cogent, and convincing evidence at adjudicatory stage).
In re Montgomery, 311 N.C. 101 (1984) (appellate review: findings supported by evidence; conclusions of law reviewed de novo).
In re C.B.C., 373 N.C. 16 (2019) (conclusions of law reviewed de novo).
In re D.L.W., 368 N.C. 835 (2016) (termination for neglect requires showing of present neglect or likelihood of future neglect).
In re Ballard, 311 N.C. 708 (1984) (past neglect alone is not always sufficient to terminate; need present or likely future neglect).
In re Z.V.A., 373 N.C. 207 (2019) (court must consider changed circumstances when assessing likelihood of future neglect).
In re E.H.P., 372 N.C. 388 (2019) (one statutory ground is sufficient to support termination).
In re T.N.H., 372 N.C. 403 (2019) (unchallenged findings are binding on appeal).