In re: K.A.

CourtCourt of Appeals of North Carolina
DecidedApril 1, 2026
Docket25-656
StatusUnpublished
AuthorJudge Jefferson Griffin

This text of In re: K.A. (In re: K.A.) 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: K.A., (N.C. Ct. App. 2026).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-656

Filed 1 April 2026

Sampson County, Nos. 24JA000098-810, 25CV001468-810

IN THE MATTER OF: K.A., minor child.

Appeal by Respondent-Mother from judgment and orders entered 31 March

2025 by Judge Mario M. White in Sampson County District Court. Heard in the

Court of Appeals 11 March 2026.

Mary McCullers Reece and Warrick & Bradshaw, P.A., by Frank L. Bradshaw, for Petitioner-Appellee Sampson County Department of Social Services.

Parent Defender Annick Lenoir-Peek, by Assistant Parent Defender Jacky Brammer, for Respondent-Appellant Mother.

Michelle FormyDuval Lynch for guardian ad litem.

GRIFFIN, Judge.

Respondent-Mother appeals the trial court’s Review Order and Order Granting

Custody and Releasing Jurisdiction in Case No. 24JA000098-810. She also appeals

the resulting Child Custody Order Pursuant to N.C. Gen. Stat. § 7B-911 Civil Custody

Order in Case No. 25CV001468-810. She argues the trial court erred because it had IN RE: K.A.

Opinion of the Court

to place the case on the permanency planning track but instead placed the case on

the review track and gave Respondent-Father full custody of their minor child,

Kourtney,1 without permanency planning hearings. We disagree and affirm the trial

court.

I. Factual and Procedural Background

On 19 July 2024, Sampson County Department of Social Services (“DSS”) filed

a juvenile petition alleging Kourtney was neglected. This petition alleged, in part, on

18 July 2023, DSS “received a Child Protective Services report regarding Neglect:

Domestic Violence, Substance Abuse and Injurious Environment of the Juveniles,”

Kourtney and her half-sibling.2 Kourtney disclosed she did “not feel safe with

Respondent-Mother’s boyfriend,” a registered sex offender whom both Kourtney and

her half-sibling disclosed had supervised them. On 31 July 2023, “a Temporary

Safety Provider moved into the home to supervise all contact between [] Respondent[-

]Mother and the Juveniles.” When that attempt failed, “the Juveniles were then

placed in a Temporary Safety Provider’s home.” On 31 July 2024, Kourtney moved

in with Respondent-Father.

On 22 October 2024, the trial court held its adjudication and dispositional

hearings and the parents, guardian ad litem, and DSS stipulated the following:

1 Kourtney is a pseudonym used by each party to protect the identity of the minor child who is

the subject of this action. See N.C. R. App. P. 42(b).

2 Kourtney’s sibling’s case is not part of this appeal.

-2- IN RE: K.A.

1. That, on July 18, 2023, [DSS] received a Child Protective Services report regarding Neglect: Domestic Violence, Substance Abuse and Injurious Environment of the Juveniles, [Kourtney] and [Kourtney’s sibling].

....

3. That, Respondent[-]Parents to the Juvenile [Kourtney] are [Respondent-Father] and [Respondent-Mother].

4. That, on July 18, 2023, the Juveniles disclosed that they do not feel safe with Respondent[-]Mother[’s] Boyfriend Donald Watts.

5. That, [] [Watts] is a registered sex offender and should not be unsupervised with children.

6. That, the Juveniles disclosed they have been supervised by [Watts].

7. That, on July 18, 2023, [t]he Juveniles disclosed that there was physical[ ]and verbal altercation between Respondent[-]Mother and [Watts] where the Juveniles had to flee.

8. That, on July 17, 2023 the Juveniles disclosed that [] Respondent[-]Mother and [Watts] fought.

9. [] Respondent[-]Mother disclosed to DSS that she did a line of methamphetamine on July 13, 2023.

10. That on July 25, 2023, Respondent[-]Mother refused to drug screen for DSS.

11. That on July 26, 2023, Respondent[-]Mother filed a no contact order on [Watts].

12. That on July 31, 2023, the Juveniles disclosed that they have seen [Watts] at the home multiple times.

13. That, the Juveniles disclosed that [] Respondent[-]

-3- IN RE: K.A.

Mother told the Juveniles to lie to DSS about [Watts] coming to the home.

14. That on July 31, 2023, a Temporary Safety Provider moved into the home to supervise all contact between [] Respondent Mother and the Juveniles.

15. That, on August 8, 2023 [] the Juveniles disclosed to DSS that [] Respondent[-]Mother has been alone with the Juveniles and the Temporary Safety Provider has not been in the home watching them.

16. That, the Juveniles were then placed in a Temporary Safety Provider’s home.

17. That, [Kourtney’s sibling] disclosed to DSS that he has been choked by [Watts] while Respondent[-]Mother was in the car.

18. That, [Watts] has criminal charges of assault on a female and stalking related to [] Respondent[-]Mother while the children were present.

19. That, [Watts] assaulted Respondent[-]Mother on April 20, 2023, and the Juveniles were present.

20. Other facts and circumstances to be presented at the hearing on the merits of this petition.

On 25 November 2024, the trial court filed an order adjudicating Kourtney

neglected based on the stipulated facts. That same day, the trial court filed its “Order

on Disposition and Order Granting Temporary Custody,” ordering “the temporary

legal and primary physical care, custody, and control of [Kourtney]” to Respondent-

Father, with whom she had been residing since 31 July 2024, and supervised visits

with Respondent-Mother. The trial court also ordered “the first review hearing”

-4- IN RE: K.A.

pursuant to N.C. Gen. Stat. § 7B-906.1 on 16 January 2025. On 24 February 2025,

after the 16 January 2025 review hearing, the trial court filed an initial review order

continuing Respondent-Father’s care, custody, and control of Kourtney and setting a

review hearing on 11 March 2025.

On 11 March 2025, the trial court held its review hearing, which Respondent-

Mother did not attend. After reviewing the evidence presented, the trial court

ordered “the care, custody, and control” of Kourtney to Respondent-Father,

terminated the Juvenile Court jurisdiction, and ordered “a civil order of custody shall

be established pursuant to the requirements of N.C. Gen. Stat. §[ ]7B-911.” The trial

court issued the section 7B-911 Custody Order on 31 March 2025.

Respondent-Mother timely appealed.

II. Analysis

The sole issue presented to the Court by Respondent-Mother is whether “the

[trial] court infringed on [Respondent-Mother’s] custodial rights and decision-making

authority over Kourtney by removing her” when the trial court “placed the case on

the review track and gave Respondent-Father full custody of Kourtney without

permanency planning hearings.” We hold the trial court did not err.

Before we begin our review, we address the GAL’s argument that this appeal

is barred by collateral estoppel. “The doctrine of collateral estoppel operates to

preclude parties ‘from retrying fully litigated issues that were decided in any prior

determination and were necessary to the prior determination.’” In re Wheeler, 87

-5- IN RE: K.A.

N.C. App. 189, 194, 360 S.E.2d 458, 461 (1987) (quoting King v. Grindstaff, 284 N.C.

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Related

Diaz v. Division of Social Services
628 S.E.2d 1 (Supreme Court of North Carolina, 2006)
King v. Grindstaff
200 S.E.2d 799 (Supreme Court of North Carolina, 1973)
Wilson v. Watson
524 S.E.2d 812 (Court of Appeals of North Carolina, 2000)
Proposed Assessments of Additional Sales v. Jefferson-Pilot Life Insurance Co.
589 S.E.2d 179 (Court of Appeals of North Carolina, 2003)
Matter of Wheeler
360 S.E.2d 458 (Court of Appeals of North Carolina, 1987)
In re B.O.A.
831 S.E.2d 305 (Supreme Court of North Carolina, 2019)
In re A.C.F.
626 S.E.2d 729 (Court of Appeals of North Carolina, 2006)

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