IN RE: G.R.R. (2024)

I. Background

Respondent-Father (“Respondent”) appeals from the trial court's order terminating his parental right to his child, G.R.R. See N.C. R. App. P. 42(b) (pseudonyms used to protect the identity of minors). Counsel for Respondent filed a no-merit brief pursuant to Rule 3.1(e) of the North Carolina Rules of Appellate Procedure. N.C. R. App. P. 3.1(e). Respondent did not exercise his opportunity to file a pro se brief in accordance with Rule 3.1(e).

II. No Merit Brief

Counsel filing a Rule 3.1(e) no-merit brief is obligated 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 identified three potential issues for our independent review: (1) whether the trial court erred by admitting Respondent's text messages over his objection; (2) whether the trial court erred by admitting a video recording of a domestic violence hearing between parties; (3) whether the trial court erred by concluding it was in the child's best interest to terminate Respondent's parental rights. Counsel has fully complied with the requirements of Rule 3.1(e).

In accordance with the holding in 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.”). Nothing tends to show any abuse of discretion or basis for reversible error in the trial court's decisions. “[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).

III. Conclusion

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

AFFIRMED.

Report per Rule 30(e).

PER CURIAM.