In re E.M., 244 N.C. App. 44 (2016)

Dismissed in part
  • Respondent mother’s challenge that the court’s findings of fact were not supported by competent evidence was not preserved for appellate review. No objection or motion to strike was made at the permanency planning review (PPR) hearing to the court’s consideration of reports and documents that were not formally offered into evidence.
  • Had the issue been preserved, there was no error because “a court holding a PPR hearing is free to consider written reports or other documentary evidence without a formal proffer or admission into evidence as exhibits.” In re J.H., 780 S.E. 2d 228, 239 (2015). 
  • The trial court properly considered the reports, and the reports, which were supplemented by witness testimony, support the challenged findings of fact.



Abuse, Neglect, Dependency
Permanency Planning Hearing
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