IN RE: A.H. Minor Child (2026)

Respondent-Father (“Father”) appeals from an order terminating his parental rights. Counsel for Father filed a no-merit brief 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, counsel fully complied with all the requirements of Rule 3.1(e).

Father's counsel identified three issues for our independent review: whether the trial court erred in concluding a ground existed to terminate Father's parental rights under N.C.G.S. § 7B-111(a)(1), (a)(2), and (a)(3).

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, 831 S.E. 2d 341, 345 (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 [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, 867 S.E. 2d 868, 870 (2022). Accordingly, we affirm the trial court's order.

AFFIRMED.

Report per Rule 30(e).

DILLON, Chief Judge.

Judges TYSON and CARPENTER concur.