In re Z.G., __ N.C.App. __ (2024)

Facts: The juvenile was adjudicated delinquent for violating a DVPO and a Level 1 disposition was entered. The adjudication order was signed by the judge on March 13, 2024, and filed with the clerk on March 18, 2024. The disposition order was entered on March 15, 2024. The juvenile appealed based on the gap in time between entry of the orders and the sufficiency of findings in the order of disposition.

Opinion:

The trial court has authority to enter a disposition order after making a determination of delinquency.

While it is better practice for the adjudication order to be fully entered prior to entry of the disposition order, entry of the disposition order before entry of the adjudication order is not error. The trial court has authority to enter a disposition order after making a determination of delinquency. In this case the trial court adjudicated the juvenile delinquent, and the adjudication order was signed before the disposition order was entered. Entry of the disposition order before entry of the adjudication order was not error.

Failure to make express written findings regarding all the factors in G.S. 7B-2501(c) in the disposition order was not error.

The order included that the trial court accepted and considered the family data sheet, risk and needs assessment, disposition tally sheet, and public safety when drafting the order. It appears from the record that the statutory factors were considered by the trial court.