Parental Termination for Anger Control Problems

In In re. N.A.L. & A.E.L., 193 N.C. App. 114, 666 S.E.2d 768, (2008), the Court reversed the termination order and remanded so that a hearing could be held to determine whether a GAL was required. Id. at 119. There, the petition alleged the children were dependent because the mother had "problems in controlling her anger outbursts; she had a significant tendency to be aggressive towards others, including her child; and she had a lack of understanding of her prior neglect of the minor child." The mother's IQ was 74; she had a personality disorder; she had borderline intellectual functioning; and she had "significant mental health issues which impacted her ability to parent the child and meet his needs." Id. at 119, 666.