In re H.H., 237 N.C. App. 431 (2014)

Affirmed in Part
Reversed in Part
Vacated in Part

"We take this opportunity to urge our district court judges to make detailed findings of fact on all competent evidence relevant to juvenile adjudications."

In the case, there were numerous reports from DSS and the GAL that were admitted without objection and incorporated by reference in the court's adjudication order. Those reports contained evidence of respondent mother's history of not providing sufficient food, heating, and stable housing for the children; not enrolling the children in school; and exposing the children to domestic violence between herself and her mother.

The incorporation by reference of those reports that were admitted without objection is not the equivalent of a finding. Had the court made additional findings of fact based on the reports, those findings would have provided a more complete context for the children's neglect adjudication, which would impact the court’s authority to order parents to take certain actions at disposition under G.S. 7B-904, such as maintain stable housing and employment.


Abuse, Neglect, Dependency
Findings of Fact
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