In In re Murphy, 105 N.C. App. 651, 414 S.E.2d 396, aff'd, 332 N.C. 663, 422 S.E.2d 577 (1992), the respondent was incarcerated at the time his parental rights were terminated. At issue on appeal was whether he had a right to be present at the hearing. This Court stated: When, as here, a parent is absent from a termination proceeding and the trial court preserves the adversarial nature of the proceeding by allowing the parent's counsel to cross examine witnesses, with the questions and answers being recorded, the parent must demonstrate some actual prejudice in order to prevail upon appeal. Id. at 658, 414 S.E.2d at 400. While Murphy indicates that the trial court must allow counsel for the absent parent to cross-examine witnesses, respondent's counsel in the present case was denied the opportunity to cross-examine witnesses, compromising the "adversarial nature of the proceeding." Id.