In re C.S.L.B., 254 N.C. App. 395 (2017) (originally unpublished but subsequently published)
Held:
Remanded
Vacated in Part
- The court may waive further permanency planning review hearings when it finds by clear and convincing evidence the five factors enumerated in G.S. 7B-906.1(n). The court erred in ceasing further review hearings as the order was silent as to one required factor: that the parties were aware that the matter could be brought into court for review by the filing of a motion or on the court’s own motion.
- The court further erred in waiving review hearings and relieving DSS and the child’s GAL of further responsibilities when reunification was a secondary plan. When reunification is a secondary plan, respondent-mother continued to have the right to have DSS provide reasonable efforts toward reunification and for the court to evaluate those efforts. See G.S. 7B-906.1(d)-(e) and 7B-906.2(b).
Category:
Abuse, Neglect, DependencyStage:
Permanency Planning HearingTopic:
Waive 7B-906.1 Hearings