In re: A.J., J.C.

CourtCourt of Appeals of North Carolina
DecidedJuly 18, 2023
Docket22-522
StatusPublished

This text of In re: A.J., J.C. (In re: A.J., J.C.) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: A.J., J.C., (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-522

Filed 18 July 2023

Pitt County, Nos. 21 JA 192–94

IN THE MATTER OF: A.J., J.C., J.C.

Appeal by respondent-mother from order entered 22 March 2022 by Judge Lee

Teague in Pitt County District Court. Heard in the Court of Appeals 13 July 2023.

The Graham Nuckolls Conner Law Firm, PLLC, by Jon G. Nuckolls, for petitioner-appellee Pitt County Department of Social Services.

North Carolina Administrative Office of the Courts, by GAL Appellate Counsel Matthew D. Wunsche and Brittany T. McKinney, for guardian ad litem.

Parent Defender Wendy C. Sotolongo, by Assistant Parent Defender Jacky L. Brammer, for respondent-appellant mother.

TYSON, Judge.

Respondent is the mother of four-year-old A.J. (“Amanda”), thirteen-year-old

J.C. (“Jade”), and fifteen-year-old J.C. (“Juliet”). See N.C. R. App. P. 42 (pseudonyms

are used throughout the opinion to protect the identity of the juveniles). She appeals

from an order entered 22 March 2022, adjudicating Amanda as a neglected juvenile,

and Jade and Juliet as neglected and dependent juveniles, and placing the children

into the custody of the Pitt County Department of Social Services (“DSS”).

Respondent argues, and we agree, the inadmissible evidence and the trial court’s

findings thereon are insufficient to support its conclusions and adjudications. We IN RE: A.J., J.C., J.C.

Opinion of the Court

reverse and remand.

I. Background

In June 2021, DSS received a report alleging neglect and improper discipline

based on an incident between Respondent and Jade. DSS created a safety plan with

Respondent, in which she agreed to refrain from physical discipline and to begin to

receive mental health services for herself and the children. Respondent also agreed

to allow Jade and Juliet to continue residing with their maternal great aunt, with

whom they had resided since 2018.

In November 2021, the Washington County Department of Social Services

(”WCDSS”) sent DSS a report of another altercation between Respondent and Jade.

On 21 December 2021, WCDSS responded to a report alleging Respondent had locked

Jade out of the house. WCDSS, DSS, and Respondent were unable to identify a

temporary safety placement for Jade.

On 22 December 2021, DSS filed juvenile petitions alleging Amanda was a

neglected juvenile and alleging Jade and Juliet were neglected and dependent

juveniles, based upon these three reported incidents. DSS also obtained nonsecure

custody of Jade, and she was placed into the care of her maternal great aunt. Juliet

remained in the voluntary care of her maternal great aunt, and Amanda, the

youngest daughter, has remained in Respondent’s care.

On 8 February 2022, DSS filed a notice it intended to present hearsay

statements at the adjudication hearing purportedly made by Jade and Juliet. DSS

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asserted their statements, made to DSS and WCDSS social workers, fell under the

residual hearsay exception of N.C. Gen. Stat. § 8C-1, Rule 803(24) (2021).

The petitions were heard on 17 February 2022. During the adjudicatory phase,

DSS presented testimony from a DSS social worker and a WCDSS social worker, each

of whom testified to statements purportedly made to them by Jade. Respondent’s

counsel objected before, during, and after the social workers introduced the hearsay

statements, but the court overruled the objections each time and allowed the

statements to be admitted into evidence.

On 22 March 2022, the trial court entered an order adjudicating all three

children as neglected juveniles and adjudicating both Jade and Juliet as dependent

juveniles. The court later determined the children’s best interests demanded for them

to be placed into DSS’ custody. Respondent timely appealed.

II. Jurisdiction

Jurisdiction lies in this Court pursuant to N.C. Gen. Stat. § 7B-1001(a)(3)

(2021).

III. Issues

Respondent argues the trial court erred by: (1) admitting hearsay statements

purportedly made by Jade, (2) adjudicating all three children as neglected, (3)

adjudicating Jade and Juliet to be dependent, and (4) concluding the children’s best

interests demanded for all of them to be removed from their parent and family and

placed into DSS custody.

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IV. Standard of Review

This Court reviews an adjudication “to determine whether the trial court’s

findings of fact are supported by clear and convincing competent evidence and

whether the court’s findings, in turn, support its conclusions of law.” In re J.R., 243

N.C. App. 309, 312, 778 S.E.2d 441, 443 (2015) (citation and internal quotation marks

omitted). “When reviewing findings of fact in a juvenile order, the reviewing court

‘simply disregards information contained in findings of fact that lack sufficient

evidentiary support’ and examines whether the remaining findings support the trial

court’s determination.” In re A.J.L.H., 384 N.C. 45, 52, 884 S.E.2d 687, 693 (2023)

(quoting In re A.C., 378 N.C. 377, 394, 861 S.E.2d 858 (2021)). The trial court’s

conclusions of law are reviewed de novo. Id.

V. Analysis

A. Findings of Fact

The trial court’s order contains eighteen adjudicatory findings of fact, eight of

which Respondent challenges in whole or in part:

5. The Department received a report relating to the Juveniles beginning on June 6, 2021, alleging neglect and improper discipline on the part of the Respondent Mother. The specific allegations were that the Juvenile, [Jade], was observed limping by another family member and later disclosed once Respondent Mother was gone that she had been in a physical altercation with the Respondent Mother. The Juvenile did not want to get out of the car and the Respondent Mother began twisting her leg trying to remove her from the car. The Juvenile locked herself in the car to get away from the Respondent Mother. The

-4- IN RE: A.J., J.C., J.C.

Respondent Mother then took a shovel and broke the window. Thereafter, the Respondent Mother beat the Juvenile with a belt buckle in the head and all over her body. She also choked and threatened to kill the Juvenile. The Respondent Mother admitted to the Department Social Worker that the altercation occurred. The Respondent Mother admitted she broke (sic) the car window in today’s testimony.

...

7. Another report was received on November 16, 2021 that the Respondent Mother had choke slammed the Juvenile, [Jade], and threw her out of the car. This incident was reportedly witnessed by a family member over a video call. During the hearing . . . Respondent Mother yelled out, “I did it.” when the choke slam was testified to.

8. On December 21, 2021, the Juvenile, [Jade], had agreed to go with Respondent Mother thinking she would be able to get her Christmas gifts and return to her [great] aunt’s home, where she had been living for several years. Instead, the Juvenile discovered that Respondent Mother planned to enroll her in school in Washington County, which upset the Juvenile.

9. On December 21, 2021, there was another report made that the Respondent Mother locked the Juvenile outside in the cold weather because she refused to babysit her two- year-old sister.

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