In re: S.R.-H.

CourtCourt of Appeals of North Carolina
DecidedJune 18, 2025
Docket24-1055
StatusUnpublished

This text of In re: S.R.-H. (In re: S.R.-H.) is published on Counsel Stack Legal Research, covering Court of Appeals 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: S.R.-H., (N.C. Ct. App. 2025).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-1055

Filed 18 June 2025

Guilford County, No. 20JT000748-400

IN THE MATTER OF:

S.R.-H.

Appeal by respondent-mother from an order terminating parental rights

entered 6 August 2024 by Judge William B. Davis in Guilford County District Court.

Heard in the Court of Appeals 23 April 2025.

Mercedes O. Chut for petitioner-appellee Guilford County Department of Health and Human Services.

Batch, Poore & Williams, PC, by Sydney Batch, for respondent-appellant mother.

FREEMAN, Judge.

Respondent-mother appeals from an order terminating her parental rights as

to S.R.-H. (“Shannon”).1 On appeal, respondent-mother’s counsel submitted a no-

merit brief pursuant to Anders v. California, 386 U.S. 738 (1967) and State v. Kinch,

314 N.C. 99 (1985), identifying proposed issues and requesting this Court determine

1 A pseudonym is used to protect the juvenile’s identity pursuant to N.C. R. App. P. 42(b). IN RE: S.R.-H.

Opinion of the Court

whether respondent-mother’s appeal wholly lacks merit. After careful review of these

identified issues and the entirety of the proceedings, we conclude this appeal is wholly

frivolous and affirm the trial court’s order terminating respondent-mother’s parental

rights.

I. Factual and Procedural Background

In October 2020, respondent-mother gave birth to Shannon. On 30 October

2020, Guilford County Department of Social Services (“DSS”) received a report

alleging that: (1) respondent-mother did not have custody of her other four children;

(2) respondent-mother was committed to a mental facility in August 2020; (3)

domestic violence was occurring in the home or in the presence of the juvenile; and

(4) respondent-mother had a history of substance abuse and mental health issues.

DSS began conducting home visits and interviews with respondent-mother and other

family members based on this report.

On 19 November 2020, DSS received an emergency report alleging abuse and

neglect of Shannon. Specifically, the emergency report alleged that respondent-

mother was dangling Shannon off a bridge, that both respondent-mother and

Shannon were dressed inappropriately for the weather, and that law enforcement

was attending the scene. DSS social workers arrived and interviewed respondent-

mother, who was sitting in a police car. Although respondent-mother recognized one

of the social workers, she appeared incoherent and stated, “I do not have time for this

right now,” and “my uterus is failing.”

-2- IN RE: S.R.-H.

DSS located Shannon in her father’s care that same day.2 Shannon’s father,

whose left eye was black and blue, and who had staples in the back of his head, denied

knowledge of the earlier bridge incident but reported multiple instances of

respondent-mother’s domestic violence, including an incident in which she hit him in

the head with a brick. According to Shannon’s father, respondent-mother got violent

when she was not taking her medication.

Based upon this incident and its investigation, DSS filed a juvenile petition on

20 November 2020 alleging that Shannon was neglected and dependent, and the trial

court signed a nonsecure custody order that day. On 2 February 2021, respondent-

mother entered into a DSS service agreement that required her to address the

following components: housing/environment/basic physical needs, employment and

income management, and mental health and parenting skills. On 8 December 2021,

the trial court adjudicated Shannon as a neglected juvenile. In March 2023,

respondent-mother’s case plan was amended to include components addressing

domestic violence and continuing employment. On 22 September 2023, based on

respondent-mother’s lack of progress, DSS filed a petition to terminate her parental

rights under subsections 7B-1111(a)(1), (2), (3), and (6) of our General Statutes.

The trial court held a hearing on the petition to terminate parental rights on

2 July 2024. In addition to considering a report and testimony from the guardian ad

2 Shannon’s father is not a party to this appeal as he did not exercise his right to appeal the

trial court’s order terminating his parental rights.

-3- IN RE: S.R.-H.

litem (“GAL”), the trial court heard testimony from social worker Christy Haik and

Shannon’s foster mother. On 6 August 2024, the trial court entered an order

terminating respondent-mother’s parental rights, concluding that DSS proved by

clear, cogent, and convincing evidence that grounds existed to terminate respondent-

mother’s parental rights under subsections 7B-1111(a)(1), (2), and (3) of our General

Statutes and that such termination would be in Shannon’s best interests.

Respondent-mother timely appealed.

II. Jurisdiction

This Court has jurisdiction to review any “order that terminates parental

rights or denies a petition or motion to terminate parental rights.”

N.C.G.S. § 7B-1001(a)(7) (2023). Accordingly, we have jurisdiction to review the trial

court’s order terminating respondent-mother’s parental rights.

III. Standard of Review

Although no-merit review pursuant to Anders v. California, 386 U.S. 738

(1967) and State v. Kinch, 314 N.C. 99 (1985) usually appears in criminal appeals,

such review is also available to a respondent-parent appealing from an order

terminating his or her parental rights. See In re L.E.M., 372 N.C. 396 (2019).

Regardless of whether the respondent-parent files a pro se brief, so long as his or her

counsel properly complies with the requirements of Anders, “such [no-merit] briefs

will, in fact, be considered by the appellate court and . . . an independent review will

be conducted of the issues identified therein.” Id. at 402. Accordingly, we

-4- IN RE: S.R.-H.

independently review the issues identified in counsel’s no-merit brief and conduct “a

full examination of all the proceedings . . . to decide whether the case is wholly

frivolous.” Anders, 386 U.S. at 744.

“We review a district court’s adjudication under N.C.G.S. § 7B-1111(a) to

determine whether the findings are supported by clear, cogent, and convincing

evidence and the findings support the conclusion of law.” In re J.S., 374 N.C. 811,

814 (2020) (cleaned up). “Unchallenged findings of fact are deemed supported by

competent evidence and are binding on appeal.” Id. “The issue of whether a trial

court’s findings of fact support its conclusions of law is reviewed de novo” and “an

adjudication of any single ground for terminating a parent’s rights . . . will suffice to

support a termination order.” Id. at 814–15. Therefore, if this Court affirms a trial

court’s conclusion “that a particular ground for termination exists, then we need not

review any remaining grounds.” Id. at 815. At the dispositional stage, “[t]he trial

court’s determination of a child’s best interests . . . is reviewed only for abuse of

discretion.” Id. at 822.

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
State v. Kinch
331 S.E.2d 665 (Supreme Court of North Carolina, 1985)
Strategic Outsourcing, Inc. v. Stacks
625 S.E.2d 800 (Court of Appeals of North Carolina, 2006)
In re L.E.M.
831 S.E.2d 341 (Supreme Court of North Carolina, 2019)
In re B.O.A.
831 S.E.2d 305 (Supreme Court of North Carolina, 2019)

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