In re L.Z.A., ___ N.C. App. ___, 792 S.E.2d 160 (2016)

  • At initial disposition, the trial court adopted a concurrent plan of reunification and adoption. Because the court did not order that reasonable efforts for reunification are not required, the court did not have to make findings of fact of at least one aggravating factor enumerated in G.S. 7B-901(c).
  • When the court orders a concurrent plan of reunification and adoption at initial disposition, the court is not required to make findings specified by G.S. 7B-906.1, which governs review and permanency planning hearings. When the court holds its permanency planning hearing, it will need to make the necessary statutory findings governing permanency planning hearings at that time.
    • Author’s Note: It appears that the court ordered concurrent planning as the initial dispositional order and did not specify that the plan was a  permanent plan.    
Abuse, Neglect, Dependency
Disposition (All Stages Post-Adjudication)
Concurrent Plan
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