147 N.C. App. 513 - In Re Frasher’s Empirical Analysis

Citation profile

14 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “deleted the "diligent efforts" requirement, indicating an intent by the legislature to eliminate the requirement that DSS provide services to a parent before a termination of parental rights can occur.... [A] determination that DSS made diligent efforts to provide services to a parent is no longer a condition precedent to terminating parental rights.”

   2 later decisions quote this exact passage
   e.g. In Re DJD · In Re JWJ

2. “G.S. 7A-289.32(3) [1995], the applicable termination statute when Harris was decided, included a requirement that DSS undertake `diligent efforts' to `encourage the parent to strengthen the parental relationship to the child or to make and follow through with constructive planning for the future of the child.'”

   1 later decision quote this exact passage
   e.g. In Re JWJ

3. “a determination that DSS made diligent efforts to provide services to a parent is no longer a condition precedent to terminating parental rights.”

   1 later decision quote this exact passage
   e.g. In Re JWJ