In re J.L., ___ N.C. App. ___, 826 S.E.2d 258 (2019)

Held: 
Affirmed in Part
Vacated and Remanded in Part
  • The standard of review of a permanency planning order is whether there is competent evidence in the record to support the findings and whether the findings support the conclusions of law. At a permanency planning hearing (PPH), the court may consider any evidence it finds to be relevant, reliable, and necessary to determine the child’s needs and most appropriate disposition. G.S. 7B-906.1(c). Mother challenges the expert doctor’s testimony that did not involve a personal evaluation of the child but was based on a review of reports and a prior PPH as insufficient, unreliable, and too speculative to support the court’s findings that the infant would suffer trauma from being removed from the only home he has ever known. The doctor’s testimony about her experience and the literature regarding child attachments and the loss of those attachments resulting in trauma and other negative consequences was sufficient competent evidence to support the findings.
Category:
Abuse, Neglect, Dependency
Stage:
Disposition (All Stages Post-Adjudication)
Topic:
Evidence
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