In re J.T., ___ N.C. App. ___, 796 S.E.2d 534 (2017)

Held: 
Vacated and Remanded
  • When a court fails to hear evidence at a permanency planning hearing, its findings of fact are not support by competent evidence. A court’s incorporation by reference of court reports (the DSS report and the GAL report) without any oral testimony from a witness are insufficient to support findings of fact. Statements by attorneys are not evidence.
Category:
Abuse, Neglect, Dependency
Stage:
Permanency Planning Hearing
Topic:
Evidence
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