In re J.W., 241 N.C. App. 44 (2015)


  • The term “non-secure” custody distinguishes it from “secure custody” in a detention facility and may be used when a juvenile is placed in DSS custody as a disposition pursuant to G.S. 7B-903(a)(2)(c).
    • Author’s Note: This opinion does not address how this differs from the use of the term “nonsecure custody” provided for in Article 5 of G.S. Chapter 7B.
  • The court did not abuse its discretion when ordering the children remain in DSS custody despite their mother completing her case plan. The court enters a disposition based upon the best interests of the children, and here the court made findings, based on competent evidence, that the mother behaved inappropriately at visits, and the conditions that resulted in the children’s removal continued to exist.


Abuse, Neglect, Dependency
Disposition (All Stages Post-Adjudication)
Custody with Department
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