In re D.C., 236 N.C. App. 287 (2014)


  • Although the permanency planning order standing alone was deficient in its required statutory findings of fact regarding cease reunification, when applying the holding of In re L.M.T., 367 N.C. 165 (2013), the termination of parental rights order cured that deficiency. Either a cease reunification permanency planning order or a termination of parental rights order standing alone or read together can be sufficient to satisfy the requirements of G.S. 7B-507(b).
  • An order is sufficient when its written findings address the substance of the statutory required factors even if the order does not use the exact language of G.S. 7B-507(b).
  • Facts: Trial court changed permanent plan to adoption and ordered a termination of parental rights petition be filed without ordering cease reunification. Respondent mother preserved her right to appeal.  Later, respondent mother’s rights were terminated, and she appealed on the grounds that the permanent planning order did not contain the required findings under G.S. 7B-507(b)(1) regarding cease reunification. The court of appeals reversed the trial court due to insufficient findings in the permanency planning order, but after the NC Supreme Court decided In re L.M.T, this case was remanded to the court of appeals for reconsideration.  
Abuse, Neglect, Dependency
Cease Reunification
Findings of Fact
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