In re A.P.W.’s Empirical Analysis

Citation profile

5 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “On 15 March 2011, the Chatham County Department of Social Services (“DSS”) filed a juvenile petition alleging that Derrick 1 was a neglected and dependent juvenile, and on 1 June 2011, the trial court adjudicated Derrick a neglected juvenile. On 18 April 2012, the trial court changed Derrick’s permanent plan to adoption and ordered that “[a] Termination of Parental Rights Motion shall be filed” [“Permanency Planning Order”]. Respondent filed notice preserving her right to appeal the 18 April 2012 order. On 24 January 2013, the trial court terminated respondent-mother’s parental rights due to neglect, failure to make reasonable progress, and failure to pay a reasonable portion of support [“TPR Order.”]. Respondent appealed the 24 January 2013 order. On appeal, respondent contends that the trial court erred in its 18 April 2012 permanency planning order by ceasing reunification efforts without entering the necessary findings of fact required by North Carolina General Statute § 7B-507(b)(1). DSS argues that the trial court never ordered the cessation of reunification efforts and, therefore, was not required to make findings under North Carolina General Statute § 7B-507(b). . . . Moreover, the trial court here changed the permanent plan to adoption, and respondent-mother properly preserved her right to appeal the cessation of reunification efforts pursuant to N.C. Gen. Stat. § 7B-507(c). This Court determined in In re A.P. W. that an order which directs the filing of a petition t”

   1 later decision quote this exact passage
   e.g. In re D.C.

2. “Although the trial court failed to make any findings regarding reasonable efforts at reunification ... the trial court effectively determined that reunification efforts ... should cease when it ordered DSS to file a petition to terminate respondent mother's parental rights.”

   1 later decision quote this exact passage
   e.g. 265 N.C. App. 454 - In re: M.T-L.Y.

3. “where a trial court failed to make any findings regarding reasonable efforts at reunification, the trial court's directive to DSS to file a petition to terminate [a parent's] parental rights implicitly also directed DSS to cease reasonable efforts at reunification.”

   1 later decision quote this exact passage
   e.g. 258 N.C. App. 422 - In re: A.A.S., A.A.A.T.