In re: J.C.

CourtCourt of Appeals of North Carolina
DecidedJune 7, 2022
Docket21-666
StatusPublished

This text of In re: J.C. (In re: 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: J.C., (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-377

No. COA21-666

Filed 7 June 2022

Cumberland County, No. 20 JA 344

IN THE MATTER OF: J.C., minor juvenile.

Appeal by Respondents from order entered 7 April 2021 by Judge Caitlyn

Evans in Cumberland County District Court and from order entered 27 July 2021 by

Judge Cheri Siler Mack in Cumberland County District Court. Heard in the Court of

Appeals 27 April 2022.

Patrick A. Kuchyt for Petitioner-Appellee Cumberland County Department of Social Services.

Richard Croutharmel for Respondent-Appellant Mother.

Parent Defender Wendy C. Sotolongo, by Assistant Parent Defender Jacky Brammer, for Respondent-Appellant Father.

K&L Gates LLP, by Leah D’Aurora Richardson, for guardian ad litem.

GRIFFIN, Judge.

¶1 Respondents appeal from orders adjudicating their minor child, Janet1, a

1We use a pseudonym to protect the identity of the juvenile and for ease of reading. See N.C. R. App. P. 42(b). MATTER OF J.C.

Opinion of the Court

neglected juvenile and continuing custody of Janet with Cumberland County

Department of Social Services. Respondents argue that the trial court’s disposition

order must be vacated because the order’s visitation provisions did not provide the

minimum duration of visits and allowed only virtual visits without making required

findings. Respondent Father argues that the trial court erred by (1) adjudicating

Janet a neglected juvenile; (2) making prejudicial statements from the bench; (3)

ordering Father to complete irrelevant case plan requirements; and (4) failing to

inform Father of his right to file a motion for review of the visitation plan.

¶2 We hold that the trial court erred by failing to inform Father of his right to file

a motion for review of the visitation order. We therefore remand this matter to the

trial court with instructions to inform Father of his right to file a motion for review.

We otherwise affirm the trial court’s orders.

I. Factual and Procedural Background

¶3 In October 2020, CCDSS filed a juvenile petition alleging that Janet was a

neglected juvenile after Respondents had “engaged in a physical altercation with each

other.” “Father stated to law enforcement that Respondent Mother was upset

because he had been drinking and [that they had] pushed each other.” After

observing “scratches” on Father, law enforcement placed Mother under arrest and

“charged [her] with simple assault.” Janet “was in Respondents’ care at the time of

the altercation but was not present.” MATTER OF J.C.

¶4 “At the time of the filing of the petition [by CCDSS],” Mother had “three older

children who [were] in the custody of CCDSS. . . . Father is the father of two of the

older children.” The older children were each “adjudicated neglected based on

Respondents’ lack of proper care . . . in that . . . Mother engaged in a physical

altercation with the oldest juvenile, Respondents would not allow the CCDSS social

worker to have access to the children, and Respondents failed to provide necessary

remedial and medical care for one of the children.”

¶5 On 10 March 2021, a hearing was held on the petition filed by CCDSS, after

which the trial court entered an order adjudicating Janet a neglected juvenile and

temporarily placing her in the custody of CCDSS. The order provided for in-person

visitation between Respondents and Janet. Following a disposition hearing, a

disposition order was entered continuing custody of Janet with CCDSS and providing

that Janet “be placed with [her] paternal grandparents [in California.]” The order

provided that “supervised virtual visitation with the juvenile . . . is in the juvenile’s

best interest” and established a virtual visitation plan.

¶6 Respondents timely filed notice of appeal from the trial court’s adjudication

and disposition orders.

II. Analysis

¶7 Respondents argue that the trial court’s disposition order must be vacated

because the order’s visitation provisions did not provide the minimum duration of MATTER OF J.C.

visits and limited visits to virtual visits only without making required findings.

Father argues that the trial court erred by (1) adjudicating Janet a neglected juvenile;

(2) making prejudicial statements from the bench; (3) ordering Father to complete

irrelevant case plan requirements; and (4) failing to inform Father of his right to file

a motion for review of the visitation plan.

A. Visitation Order

¶8 Respondents argue that the trial court erred by (1) failing to provide the

minimum duration of visits in the disposition order and (2) limiting all visits to

virtual visits only without making required findings. We disagree.

¶9 “We review disposition orders, including visitation determinations, for abuse

of discretion. When reviewing for abuse of discretion, we defer to the trial court’s

judgment and overturn it only upon a showing that it was so arbitrary that it could

not have been the result of a reasoned decision.” Matter of K.W., 272 N.C. App. 487,

495, 846 S.E.2d 584, 590 (2020) (citations omitted).

1. Minimum Duration of Visits

¶ 10 With respect to the minimum duration of visits, N.C. Gen. Stat. § 7B-905.1(b)

provides:

If the juvenile is placed or continued in the custody or placement responsibility of a county department of social services, the court may order the director to arrange, facilitate, and supervise a visitation plan expressly approved or ordered by the court. The plan shall indicate MATTER OF J.C.

the minimum frequency and length of visits and whether the visits shall be supervised.

N.C. Gen. Stat. § 7B-905.1(b) (2021).

¶ 11 The trial court’s disposition order contained the following visitation provisions:

10. Respondent Parents are hereby authorized virtual visits with the juvenile at 12 p.m. on Thursdays, with 24- hour notice. If no notice is given, there shall be no visits.

11. When the juvenile is placed in California [with her grandparents], Respondent Parents are authorized virtual/telephone visits up to (30) thirty minutes, two times per week.

...

14. The Court’s previous orders not inconsistent with this order shall remain in effect.

¶ 12 Respondents argue that, by not stating the specific duration of visits in

paragraph No. 10 above, the trial court committed reversible error. However,

Respondents overlook that paragraph No. 14 states that “previous orders not

inconsistent with this order shall remain in effect.” The disposition order further

stated that “the [c]ourt incorporates all the previous findings made from the

Adjudication Hearing heard on March 10, 2021, as if set forth fully herein.” In the

order entered pursuant to that hearing, the trial court ordered that “Respondent

Parents shall receive one (1) hour supervised visitation with the juvenile once a week,

supervised by [CCDSS].” (Emphasis added). MATTER OF J.C.

¶ 13 “Viewing the[] two orders in conjunction, it is clear that the visitation plan

authorizes supervised[]” virtual visits, once per week, for one hour. In re L.Z.A., 249

N.C. App. 628, 639, 792 S.E.2d 160, 169 (2016) (affirming a visitation plan in a

disposition order where the order referred to a previous visitation plan which

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Related

In re: T.G.
781 S.E.2d 93 (Court of Appeals of North Carolina, 2015)
In re: J.L.
826 S.E.2d 258 (Court of Appeals of North Carolina, 2019)
In re T.H.T.
648 S.E.2d 519 (Court of Appeals of North Carolina, 2007)
In re L.Z.A.
792 S.E.2d 160 (Court of Appeals of North Carolina, 2016)
In re T.W.
796 S.E.2d 792 (Court of Appeals of North Carolina, 2016)
In re T.R.T.
737 S.E.2d 823 (Court of Appeals of North Carolina, 2013)

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