In the Matter of V.M., 211 N.C. App. 389 (2011)

The Court of Appeals reversed and remanded for a new disposition hearing because the trial court simply checked pre-printed boxes on the disposition order but entered no additional findings to demonstrate that it considered the G.S. 7B-2501(c) factors. Based on the juvenile’s admission to a probation violation and a new offense, the court entered a Level 3 disposition, “based on the probation violation.” The disposition order noted that the court received, considered, and incorporated by reference the predisposition report and risk and needs assessments, but the court failed to make findings of fact sufficient to show that it considered the factors set out in G.S. 7B-2501(c). Because a probation violation proceeding is a dispositional proceeding, the order must comply with requirements for a disposition order. Every disposition order must contain “appropriate findings of fact and conclusions of law.”