In re J.C., 235 N.C. App. 69 (2014)

  • Although written findings of fact regarding jurisdiction of NC being the child’s home state under the UCCJEA is best practice, G.S. 50A-201 does not require written findings but rather only requires that circumstances for jurisdiction must exist. Evidence supporting those circumstances is sufficient to establish subject matter jurisdiction under the UCCJEA.
  • Facts: Kentucky issued custody order regarding the children in 2008. The family moved to North Carolina in 2011 and have continuously resided in NC since then. In 2013, dss filed a petition alleging the children were neglected and dependent. Respondent mother appealed the adjudication in part on a lack of subject matter jurisdiction.


Note, reversed on other grounds (disposition), In re J.C., 368 N.C. 89 (2015)

Subject Matter Jurisdiction
Home State
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