In re E.M., 249 N.C. App. 44 (2016)


·         GS 7B-906.1(n) authorizes the court to waive permanency planning hearings when it finds each of the five statutory enumerated factors by clear, cogent, and convincing evidence. It is reversible error when the court does not (1) make written findings of each factor or (2) identify the burden of proof it applied on the record (e.g., included in the written order or stated in open court) or the “record when viewed in its entirety clearly reveals the court applied the proper evidentiary standard.” [In re M.D., 200 N.C. App 35, 39 (2009)]. Here, only one factor was found and it is unknown what standard of proof was used.

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