In re: A.H.

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA No. COA 25-471 Filed 4 March 2026 Durham County, No. 20JA000163-310 IN THE MATTER OF: A.H.

Minor Child Appeal by respondent-appellant from judgment entered 20 December 2024 by Judge Kendra Montgomery-Blinn in Durham County District Court. Heard in the Court of Appeals 28 January 2026.

Mercedes O. Chut for respondent-appellant father.

Michelle FormyDuval Lynch for guardian ad litem.

No brief filed by petitioner-appellee Durham County Department of Social Services.

DILLON, Chief Judge.

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 IN RE: A.H.

Opinion of the Court 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.

Judges TYSON and CARPENTER concur.

Report per Rule 30(e).

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