In re: K.C.

CourtCourt of Appeals of North Carolina
DecidedMay 2, 2023
Docket22-396
StatusPublished

This text of In re: K.C. (In re: K.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: K.C., (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-396

Filed 02 May 2023

Durham County, No. 20 JA 116

IN THE MATTER OF: K.C.

Appeal by respondent-father from orders entered 21 October 2021 and 8

February 2022 by Judge Doretta L. Walker in Durham County District Court. Heard

in the Court of Appeals 3 April 2023.

Robin K. Martinek, for Durham County Department of Social Services, petitioner-appellee.

Alston & Bird LLP, by Kelsey L. Kingsbery and Michelle C. Prendergast, for the Guardian ad Litem.

Richard Croutharmel, for the father, respondent-appellant.

WOOD, Judge.

Respondent-father appeals from the disposition order placing K.C. (“Katy”)1 in

the temporary custody of the paternal aunt and uncle following the trial court’s

adjudication of Katy as a neglected juvenile. For the reasons stated herein, we vacate

the disposition order and remand for further proceedings.

I. Background

1 A pseudonym agreed upon by the parties pursuant to N.C. R. App. P. 42(b). IN RE K.C.

Opinion of the Court

Katy was born in January 2020. On 25 August 2020, Durham County

Department of Social Services filed a petition alleging Katy to be a neglected juvenile.

The petition alleged Katy and her mother2 both tested positive for marijuana at

Katy’s birth, and that mother admitted to using cocaine during her pregnancy.

Mother had a history of mental health, substance abuse, and domestic violence issues,

as well as a history of housing instability. On 9 August 2020, mother was charged

with driving while impaired and reckless endangerment after she fled the scene of an

automobile accident. Following this incident, DSS and the parents established a

safety plan for Katy whereby Katy would be placed with respondent-father, the non-

offending parent, with whom she has had regular visits since birth. The only mention

of Respondent in the petition states that he is the father of Katy and had regular

visitation with her until she was placed with him pursuant to the safety plan. DSS

did not seek non-secured custody of Katy.

On 15 October 2021, more than a year after the filing of the juvenile petition,

the matter came on for adjudication. On 21 October 2021, the trial court entered an

order adjudicating Katy to be a neglected juvenile. The dispositional hearing was

held on 10 December 2021. This is the first time the court contemplated

removal of the child from the non-offending parent. On 13 January 2022, the

trial court entered a limited order placing Katy in the temporary custody of her

2 Katy’s mother is not a party to this appeal.

-2- IN RE K.C.

paternal aunt and uncle. The trial court entered the formal disposition order on 8

February 2022, wherein it formally placed Katy in the “temporary custody” of her

paternal aunt and uncle and ordered Respondent to complete a parenting class with

a domestic violence component, complete a domestic violence program for

perpetrators, refrain from physically disciplining Katy, maintain contact with the

social worker, maintain stable housing, maintain employment and income, refrain

from using illegal substances, sign all necessary releases to allow the social worker

to access service records, and ensure that all service providers have copies of the trial

court’s orders. He was granted up to three hours of weekly, unsupervised visitation

with Katy. Respondent appeals.

II. Discussion

On appeal, Respondent argues the trial court erred in placing Katy in the

temporary custody of the paternal aunt and uncle where its determination that he

acted inconsistently with his constitutional rights as a parent was not supported by

the evidence or the findings of fact. Respondent’s argument has merit.

We begin by noting that Respondent properly preserved this issue for our

review.3 Respondent had notice that DSS was recommending temporary custody of

Katy be placed with the paternal aunt and uncle. At the dispositional hearing, he

3 On 28 June 2022, DSS filed a motion to dismiss respondent’s appeal on the ground that respondent had failed to preserve his sole argument on appeal for review. Petitioner’s motion to dismiss is denied.

-3- IN RE K.C.

opposed DSS’s recommendation, testified that he had the ability to care for Katy, and

specifically requested the court to allow Katy to remain in his custody. See In re

B.R.W., 278 N.C. App. 382, 399, 863 S.E.2d 202, 216 (2021) (holding that the

respondent-mother’s challenge to the trial court’s determination that she acted

inconsistently with her protected status was preserved where she presented evidence

of her ability to care for the children, opposed the recommendation of guardianship,

and requested the trial court to reject the recommendation of guardianship), aff’d,

381 N.C. 61, 871 S.E.2d 764 (2022).

Here, the trial court determined that Respondent had “acted inconsistent[ly]

with [his] constitutional right [as a] parent.” Respondent initially contends that the

trial court erred in labeling this determination as a finding of fact when it is a

conclusion of law. We agree. Although the trial court characterized this

determination as a finding of fact, it is a conclusion of law; and we review it

accordingly. See In re J.S., 374 N.C. 811, 818, 845 S.E.2d 66, 73 (2020) (“We are

obliged to apply the appropriate standard of review to a finding of fact or conclusion

of law, regardless of the label which it is given by the trial court.”). “The trial court’s

legal conclusion that a parent acted inconsistently with his constitutionally protected

status as a parent is reviewed de novo to determine whether the findings of fact

cumulatively support the conclusion and whether the conclusion is supported by clear

and convincing evidence.” In re I.K., 377 N.C. 417, 421, 858 S.E.2d 607, 611 (2021).

The Due Process Clause of the Fourteenth Amendment to the United States

-4- IN RE K.C.

Constitution protects “a natural parent’s paramount constitutional right to custody

and control of his or her children” and ensures that “the government may take a child

away from his or her natural parent only upon a showing that the parent is unfit to

have custody” or “where the parent’s conduct is inconsistent with his or her

constitutionally protected status.” Adams v. Tessener, 354 N.C. 57, 62, 550 S.E.2d

499, 503 (2001). A parent’s constitutionally protected interest

in the companionship, custody, care, and control of his or her child is a counterpart of the parental responsibilities the parent has assumed and is based on the presumption that he or she will act in the best interest of the child. Therefore, the parent may no longer enjoy a paramount status if his or her conduct is inconsistent with this presumption or if he or she fails to shoulder the responsibilities that are attendant to rearing a child.

Price v. Howard, 346 N.C. 68, 79, 484 S.E.2d 528, 534 (1997). “[T]here is no bright

line beyond which a parent’s conduct” constitutes action inconsistent with their

protected status. Boseman v. Jarrell, 364 N.C. 537, 549, 704 S.E.2d 494, 503 (2010).

“Unfitness, neglect, and abandonment clearly constitute conduct inconsistent with

the protected status parents may enjoy. Other types of conduct, which must be

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Related

Price v. Howard
484 S.E.2d 528 (Supreme Court of North Carolina, 1997)
Adams v. Tessener
550 S.E.2d 499 (Supreme Court of North Carolina, 2001)
Owenby v. Young
579 S.E.2d 264 (Supreme Court of North Carolina, 2003)
Raynor v. Odom
478 S.E.2d 655 (Court of Appeals of North Carolina, 1996)
Jolly v. Queen
142 S.E.2d 592 (Supreme Court of North Carolina, 1965)
Matter of Evans
344 S.E.2d 325 (Court of Appeals of North Carolina, 1986)
Boseman v. Jarrell
704 S.E.2d 494 (Supreme Court of North Carolina, 2010)
In Re DM
712 S.E.2d 355 (Court of Appeals of North Carolina, 2011)
In re T.L.H.
772 S.E.2d 451 (Supreme Court of North Carolina, 2015)
In re B.W.
665 S.E.2d 462 (Court of Appeals of North Carolina, 2008)
In re E.B.
775 S.E.2d 693 (Court of Appeals of North Carolina, 2015)
In re M.L.B.
775 S.E.2d 695 (Court of Appeals of North Carolina, 2015)
In re D.M.
211 N.C. App. 382 (Court of Appeals of North Carolina, 2011)

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