In re S.R.J.T., 276 N.C. App. 327 (2021)

Reversed and remanded in part
Affirmed in Part
There is a dissent.
  • SUPERSEDED BY 2021-NCCOA-433 (August 17, 2021) (unpublished) 
  • Facts: In 2017, the child was adjudicated neglected and dependent due to circumstances of drug abuse and domestic violence in the home. The dispositional order ceased reunification efforts, granted guardianship to the aunt, and suspended visitation and further hearings. Mother appeals both the adjudication and disposition.
  • Standard of review for an adjudication is whether the findings are supported by clear and convincing evidence and whether the findings support the conclusion of law. Conclusions of law are reviewed de novo.
  • G.S. 7B-101(15) defines neglect in part as a juvenile who lives in an injurious environment to his welfare. There must be harm or a substantial risk of harm to the child, but “failure to make specific findings regarding a child’s impairment or risk of harm will not require reversal where the evidence supports such findings.” 276 N.C. App. at 338.
  • The findings are supported by evidence and support the conclusion. There is evidence that the child is suffering with PTSD. “We affirm the trial court’s adjudication of neglect on this basis and need not address the other adjudicatory grounds in the court’s order.” 276 N.C. App. at 334.
Abuse, Neglect, Dependency
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