In re A.A.

CourtSupreme Court of North Carolina
DecidedJune 17, 2022
Docket441A20
StatusPublished

This text of In re A.A. (In re A.A.) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re A.A., (N.C. 2022).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

2022-NCSC-66

No. 441A20

Filed 17 June 2022

IN THE MATTER OF: A.A.

Appeal pursuant to N.C.G.S. § 7B-1001(a1)(1) (2019) from an order entered on

12 August 2020 by Judge Marion Boone in District Court, Surry County. Heard in

the Supreme Court on 5 October 2021.

James N. Freeman Jr. for petitioner-appellee.

No brief for appellee Guardian ad Litem.

Peter Wood for respondent-appellant mother.

MORGAN, Justice.

¶1 In this private termination of parental rights case, we consider issues of the

trial court’s subject matter jurisdiction and its substantive determinations in the

proceeding. First, we address the question of whether petitioner, as the stepmother

of the juvenile who is the focus of this matter, had standing to bring a private

termination of parental rights action against respondent-mother, the child’s

biological mother. If we conclude that petitioner had standing to initiate the

termination action, then we must additionally consider respondent-mother’s

arguments that the trial court erred (1) in finding that the ground of abandonment

existed for termination of parental rights, and (2) in concluding that termination of IN RE A.A.

Opinion of the Court

respondent-mother’s parental rights was in the child’s best interests.

¶2 Upon careful review, we hold that petitioner satisfied the relevant statutory

requirements to file a private petition for termination of parental rights. We further

conclude that clear, cogent, and convincing evidence of abandonment, as defined in

both statutory law and case law, was presented at the adjudication hearing to

establish that this ground existed for the termination of respondent-mother’s

parental rights. Lastly, the trial court did not abuse its discretion in concluding that

it was in the child’s best interests to terminate the parental rights of respondent-

mother. Accordingly, we affirm the trial court’s order terminating respondent-

mother’s parental rights.

I. Factual Background and Procedural History

¶3 Respondent-mother gave birth to a daughter “Amy” on 5 August 2010.1 Amy’s

father was granted primary custody of Amy in 2012. Petitioner and Amy’s father

became involved in a romantic relationship in October 2013, and petitioner, Amy’s

father, and Amy began residing together later in the year. On 30 April 2015,

petitioner and Amy’s father married each other; the couple had two children together:

a son born in April 2015 and a daughter born in March 2017. Petitioner and Amy’s

father separated in October 2017 and became divorced on 14 January 2019.

1 We employ a pseudonym for the juvenile to protect her privacy and for ease of reading. IN RE A.A.

¶4 On 31 May 2018, petitioner filed an action against respondent-mother and

Amy’s father in District Court, Surry County, seeking full custody of Amy. In the

custody complaint, petitioner alleged that respondent-mother and Amy’s father were

incarcerated in the Surry County Jail at the time of the filing of the action and that

Amy had continued to live with petitioner since petitioner’s marriage to the father,

even after petitioner and Amy’s father separated. Petitioner further alleged the

occurrence of two incidents of domestic violence by Amy’s father toward petitioner in

the presence of one or more of the children. Petitioner stated that after the father

exercised visitation with Amy and one of Amy’s half-siblings on 22 January 2018,

petitioner and Amy’s father had a verbal argument which resulted in a “physical

outburst” by the father and his destruction of petitioner’s kitchen table and chairs in

the presence of their youngest child. Petitioner also described an altercation on 1 May

2018 between the father and their two biological children which transpired during a

visit to a fast-food restaurant, leading petitioner to seek criminal charges against the

father and to seek a domestic violence protective order. Amy’s father was arrested

later in the day after picking up Amy early from school and then, with Amy in his

car, circling the domestic violence office in Surry County where petitioner was

discussing the domestic violence incident at the fast-food restaurant which had

occurred.

¶5 On 31 May 2018, petitioner was granted temporary legal and physical custody IN RE A.A.

of Amy, and on 23 July 2018, petitioner was granted exclusive legal and physical

custody of Amy upon the trial court’s finding that respondent-mother and Amy’s

father had “acted contrary to their constitutionally protected status as biological

parents.” Respondent-mother was granted two hours of supervised visitation with

Amy weekly. However, respondent-mother did not utilize the visitation with the

juvenile which was available to her and had only one in-person visit with Amy over

the course of the next eleven months. Although respondent-mother requested a visit

with Amy on 6 August 2018—the day after Amy’s birthday—respondent-mother was

not punctual in her arrival for the visit at the location where petitioner and

respondent-mother had agreed that the visit would occur, which was a local library.

Respondent-mother also failed to attend a court-ordered custody mediation regarding

Amy in late September 2018. Respondent-mother did have a visit with Amy on 23

September 2018. On 25 September 2018, respondent-mother requested another visit

with the child, but when petitioner asked respondent-mother to send a text message

to petitioner during the following week in order to arrange details of the proposed

visit, respondent-mother did not do so. The next contact which petitioner had with

respondent-mother occurred on 12 May 2019, which was Mother’s Day. On this

occasion, respondent-mother sent the following text message to petitioner: “This is

[respondent-mother]. Happy Mother’s Day. Thank you for always loving mine and

treating mine as your own.” IN RE A.A.

¶6 On 13 May 2019, petitioner filed a private petition to terminate respondent-

mother’s parental rights to Amy, alleging willful abandonment of the minor child

within the meaning of N.C.G.S. § 7B-1111(a)(7) as the grounds for termination.

Petitioner alleged that respondent-mother did not exercise respondent-mother’s

visitation rights with Amy at any time after 23 September 2018, that respondent-

mother also chose not to send Amy any gifts, cards, or other correspondence from this

identified juncture, and that respondent-mother never attempted to communicate

with Amy by telephone or any other means.

¶7 During the adjudication hearing which took place on 24 July 2020,2 petitioner

testified that she had heard nothing from respondent-mother for eight months after

September 2018 until respondent-mother sent petitioner the aforementioned

Mother’s Day text message on 12 May 2019. On this occasion, however, respondent-

mother did not ask to speak to Amy or inquire about Amy’s wellbeing. Although

respondent-mother had a mailing address for Amy and knew petitioner’s telephone

number, nonetheless Amy never received any cards, gifts, food, clothing, or other

items from respondent-mother; respondent-mother never assisted with Amy’s school,

medical, or emotional needs; and in the handful of text messages that respondent-

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