In re W.C.T., 280 N.C. App. 17 (2021)

  • Facts: This case involves 3 children, the youngest whom suffered second and third degree burns when he was 3 months old and was being watched by his paternal grandmother, with whom the parents and children lived. The infant’s injuries were not witnessed but various inconsistent and implausible explanations were provided. DSS became involved and ultimately filed a petition alleging the infant was abused, neglected, and dependent and his 2 siblings were neglected and dependent. After hearing, the juveniles were adjudicated as alleged. At initial disposition, the children were placed in DSS custody. Both parents appeal. Mother challenges disposition as well as adjudication.
  • At disposition, the court has the authority to order a parent to take appropriate steps to remedy the conditions that led to the child’s adjudication or removal from the home. G.S. 7B-904(d1)(3). Mother was ordered to take steps that were reasonably related to the chidren’s removal. Showing proof of income is reasonably related to ensuring the children have adequate care and supervision to reduce the risk factors and ensure the children have a safe home. The provision that mother must refrain from allowing mental health to impact parenting is also reasonably related to the conditions that led to the children’s adjudication given mother conspiring to make an explanation for one child’s injury and the suspected domestic violence in the home.
Abuse, Neglect, Dependency
Disposition (All Stages Post-Adjudication)
Court Authority to Order Case Plan
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