In re M.S.L., 380 N.C. 778 (2022)

  • Facts: Father challenges the termination of his parental rights, arguing the court lacked subject matter jurisdiction because G.S. 7B-1101 requires the court make specific findings that it has jurisdiction. Father concedes that the record supports a conclusion that the district court has subject matter jurisdiction, and the TPR order states “[t]he Court has jurisdiction over the parties and subject matter of this action.” 380 N.C. at 782.
  • Although G.S. 7B-1101 states “the court shall find that it has jurisdiction to make a child-custody determination under the provisions of G.S. 50A-201, 50A-203, or 50A-204[,]” the finding does not need to explicitly mirror the statutory language. The general statement the court had personal and subject matter jurisdiction and the records supports that statement is sufficient.
Termination of Parental Rights
Subject Matter Jurisdiction
G.S. 7B Jurisdiction
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