In re C.S.L.B., ___ N.C. App. ___, 803 S.E.2d 429 (2017) (originally unpublished but subsequently published)

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).
Abuse, Neglect, Dependency
Permanency Planning Hearing
Waive 7B-906.1 Hearings
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