In re H.L., ___ N.C. App. ___, 807 S.E.2d 685 (2017)

Held: 
Reversed in Part
  • The court must make findings addressing both prongs of the dependency definition at G.S. 7B-101(9): the parent’s ability to provide proper care or supervision and the availability of an alternative child care arrangement. The court’s order did not contain findings about either prong. Regarding the first prong, the findings supporting the court’s adjudication of neglect was based on the creation of an injurious environment to the juvenile and did not include findings that the parent’s “behaviors rendered them wholly unable to parent” to satisfy the dependency prong. 
Category:
Abuse, Neglect, Dependency
Stage:
Adjudication
Topic:
Dependency
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