In re F.C.D., 244 N.C. App. 243 (2015)



  • The findings are supported by competent evidence and support the conclusion that the child was abused.
  • A juvenile is abused when his or her parent, guardian, custodian, or caretaker uses or allows to be used upon him or her cruel or grossly inappropriate procedures or devices to modify his or her behavior. G.S. 7B-101(1)c. This definition focuses on the severity and brutality of the procedures and devices that are used by the parent, guardian, custodian, or caretaker and does not examine the child’s behavior that the procedures or devices were meant to correct.
  • The following procedures constitute abuse: forcing the child to sleep outside on at least two cold nights in February, binding the child to a tree, ordering the child to pray while the caretaker held a firearm, requiring the child to conduct a self-baptism in a bathtub of water, striking the child with a belt all over his body, and telling the child he was possessed by a demon such that the child began to believe it was true.


Abuse, Neglect, Dependency
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