IN RE: G.T.N. (2025)

Respondent-Mother (“Mother”) and Respondent-Father (“Father”) appeal from identical Adjudication and Disposition orders terminating their parental rights. Counsel for both Mother and Father filed a no-merit briefs under Rule 3.1(e) of the North Carolina Rules of Appellate Procedure.

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.” N.C. R. App. P. 3.1(e) (2023). Here, both counsel fully complied with all the requirements of Rule 3.1(e).

Mother's counsel identified two issues for our independent review: (1) whether the trial court had the jurisdiction to hold a termination hearing and (2) whether the trial court erred in terminating Mother's parental rights solely based on neglect.

Father's counsel also identified two issues for our independent review: (1) whether there was competent evidence sufficiently clear, cogent, and convincing to support the trial court's finding of fact, and whether the findings of fact were sufficient to support the trial court's conclusions of law to terminate Father's parental rights; and (2) whether the trial court abused its discretion by concluding that Father's termination of parental rights was in the best interests of the child.

This Court conducts an independent review of the issues raised in the no-merit brief. In re L.E.M., 372 N.C. 396, 402 (2019). “[T]he text of Rule 3.1([e]) plainly contemplates appellate review of the issues contained in a no-merit brief.” Id. “[W]e are satisfied that the trial court's order terminating [both Mother's and Father'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, (2022). Accordingly, we affirm the trial court's order.

AFFIRMED.

Report per Rule 30(e).

PER CURIAM.