In re J.H., 244 N.C. App. 255 (2015)

Vacated and Remanded

** Note the court of appeals vacated and remanded this case to determine whether subject matter jurisdiction existed under the UCCJEA. The court of appeals also addressed the issues raised on appeal that were unrelated to subject matter jurisdiction in the event the trial court, on remand, determined it did have jurisdiction.

  • Dispositional hearings (in this case a permanency planning hearing) are not governed by the Rules of Evidence. A report may be submitted to and considered by the court without a formal proffer and admission into evidence as exhibits. When reports are received by the court, a party must object to the court’s consideration of the report at the hearing in order to preserve the issue of the court’s consideration of the report for an appeal.
Abuse, Neglect, Dependency
Disposition (All Stages Post-Adjudication)
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