In the Matter of B.o.a.

Summary

The Supreme Court of North Carolina reversed the Court of Appeals' decision, which had overturned a trial court's termination of respondent-mother Lauren B.'s parental rights to her daughter B.O.A. under N.C.G.S. § 7B-1111(a)(2) for failure to make reasonable progress in correcting the conditions that led to the juvenile's removal. The Supreme Court held that the 'conditions which led to the removal of the juvenile' under § 7B-1111(a)(2) include all factors that directly or indirectly contributed to causing the removal, not merely those explicitly alleged in the initial petition or the triggering event. Because the record showed a nexus between respondent-mother's mental health, substance abuse, and medication management issues and the domestic violence-related conditions that led to removal, and because her unchallenged findings of fact demonstrated minimal compliance with her court-ordered case plan, the trial court's conclusion that she failed to make reasonable progress was adequately supported.