IN RE: J.G. (2024)

Respondent-Mother appeals from the trial court's 26 September 2023 order terminating her parental rights to her two children, J.G. and J.G. See N.C. R. App. P. 42(b) (pseudonyms used to protect the identity of minors). Counsel for Mother filed a no-merit brief under Rule 3.1(e) of the North Carolina Rules of Appellate Procedure. N.C. R. App. P. 3.1(e). Mother did not exercise her opportunity to file a pro se brief in accordance with Rule 3.1(e).

Counsel filing a Rule 3.1(e) no-merit brief is required to “identify any issues in the record on appeal that arguably support the appeal and must state why those issues lack merit or would not alter the ultimate result.” Id.

Counsel fully complied with all of the requirements of Rule 3.1(e) and identified three potential issues for our independent review: (1) whether the trial court abused its discretion by failing to appoint Respondent-Mother a Rule 17 Guardian Ad Litem until before the Termination of Parental Rights Hearing; (2) whether the trial court reversibly erred by concluding grounds existed to terminate Respondent-Mother's parental rights because the evidence failed to support the findings and the findings failed to support the conclusions; and, (3) whether the trial court abused its discretion by terminating parental rights because termination was not in the best interests of the juveniles.

In accordance with In re L.E.M., we have conducted an independent review of the potential issues raised in the no-merit brief. In re L.E.M., 372 N.C. 396, 402, 831 S.E.2d 341, 345 (2019) (“We conclude that the text of Rule 3.1([e]) plainly contemplates appellate review of the issues contained in a no-merit brief.”). “[W]e are satisfied that the trial court's order terminating respondent's parental rights is supported by clear, cogent, and convincing evidence and is based on proper legal grounds.” In re K.M.S., 380 N.C. 56, 59, 867 S.E.2d 868, 870 (2022).

We affirm the trial court's order terminating Respondent-Mother's parental rights. Id. It is so ordered.

AFFIRMED.

Report per Rule 30(e).

PER CURIAM.