In re L.T.

CourtSupreme Court of North Carolina
DecidedJune 5, 2020
Docket274A19
StatusPublished

This text of In re L.T. (In re L.T.) is published on Counsel Stack Legal Research, covering Supreme Court 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 L.T., (N.C. 2020).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 274A19

Filed 5 June 2020

IN THE MATTER OF: L.T.

Appeal pursuant to N.C.G.S. § 7B-1001(a1)(1) from an order entered on

22 March 2019 by Judge Aretha V. Blake in District Court, Mecklenburg County.

This matter was calendared for argument in the Supreme Court on 18 May 2020 but

determined on the record and briefs without oral argument pursuant to Rule 30(f) of

the North Carolina Rules of Appellate Procedure.

Keith T. Roberson for petitioner-appellee Mecklenburg County Department of Social Services.

Matthew D. Wunsche, GAL Appellate Counsel, for appellee Guardian ad Litem.

J. Thomas Diepenbrock for respondent-appellant father.

BEASLEY, Chief Justice.

Respondent-father appeals from the trial court’s order terminating his

parental rights to his daughter, Laurie.1 After careful consideration of respondent-

father’s challenge to the trial court’s jurisdiction, we affirm the termination order.

On 17 March 2017, the Mecklenburg County Department of Social Services

(DSS) filed a petition alleging that Laurie was a neglected and dependent juvenile.

The petition also alleged that Laurie’s mother lived in Ohio and that Laurie lived

1 Pseudonyms are used to protect the identity of the juvenile and for ease of reading. IN RE L.T.

Opinion of the Court

with respondent-father in Charlotte, North Carolina. DSS believed Laurie was at a

substantial risk of injury if she remained in respondent-father’s care.

On 12 June 2017, the trial court entered a continuance order. It found that

prior to the scheduled adjudication hearing on 23 May 2017, respondent-father’s

attorney and the guardian ad litem (GAL) attorney advocate informed the court that

Laurie had not lived in North Carolina for six months before the juvenile petition was

filed and that there appeared to be a valid custody order from Delaware in effect that

granted sole custody to respondent-father. The trial court also found that neither

Laurie’s mother nor respondent-father was still living in Delaware. The court

continued the case in order to investigate whether it had jurisdiction under the

Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA or the Act).

The matter came on for adjudication and disposition on 26 July and 3 August

2017. On 21 September 2017, the trial court entered an order concluding that Laurie

was a neglected and dependent juvenile. In the order, the court also found that Laurie

and respondent-father had resided in Charlotte since September 2016 and concluded

that it had jurisdiction over the case.

On 19 September 2018, DSS filed a motion in the cause to terminate

respondent-father’s parental rights on the grounds of neglect and willfully leaving

Laurie in foster care for more than twelve months without making adequate progress

to correct the removal conditions. See N.C.G.S. § 7B-1111(a)(1)–(2) (2019). On

22 March 2019, the trial court entered an order terminating respondent-father’s

-2- IN RE L.T.

rights pursuant to N.C.G.S. § 7B-1111(a)(2). The court also concluded that

termination was in Laurie’s best interest. Respondent-father appealed.

Respondent-father argues that the trial court lacked jurisdiction to enter its

termination order. He contends that the trial court failed to comply with the

requirements of the UCCJEA when it learned of the Delaware custody order at the

beginning of this case and that all the proceedings involving Laurie in North Carolina

are therefore void. We disagree.

Because a court must have subject matter jurisdiction in order to adjudicate

the case before it, “a court’s lack of subject matter jurisdiction is not waivable and can

be raised at any time.” In re K.J.L., 363 N.C. 343, 346, 677 S.E.2d 835, 837 (2009)

(citations omitted). This Court presumes the trial court has properly exercised

jurisdiction unless the party challenging jurisdiction meets its burden of showing

otherwise. In re S.E., 838 S.E.2d 328, 331 (N.C. 2020).

The trial court must comply with the UCCJEA in order to have subject matter

jurisdiction over juvenile abuse, neglect, and dependency cases and termination of

parental rights cases. Id.; see also N.C.G.S. § 7B-1101 (2019). The trial court is not

required to make specific findings of fact demonstrating its jurisdiction under the

UCCJEA, but the record must reflect that the jurisdictional prerequisites in the Act

were satisfied when the court exercised jurisdiction. See In re T.J.D.W., 182 N.C. App.

394, 397, 642 S.E.2d 471, 473, aff’d per curiam, 362 N.C. 84, 653 S.E.2d 143 (2007).

-3- IN RE L.T.

The parties agree that Laurie was the subject of a valid Delaware child custody

order when DSS filed the initial neglect and dependency petition on 17 March 2017.

Their dispute is whether the trial court had jurisdiction to modify the Delaware order.

Respondent-father contends that the record shows the trial court lacked modification

authority under the Act.

Section 50A-203 of the North Carolina General Statutes governs when the trial

court has jurisdiction to modify an out-of-state custody order under the UCCJEA. It

sets out a two-part test for establishing modification jurisdiction: first, the trial court

must have jurisdiction to make an initial custody determination under N.C.G.S.

§ 50A-201(a)(1) or (2), and second, one of the following must have occurred:

(1) The court of the other state determines it no longer has exclusive, continuing jurisdiction under G.S. 50A-202 or that a court of this State would be a more convenient forum under G.S. 50A-207; or (2) A court of this State or a court of the other state determines that the child, the child’s parents, and any person acting as a parent do not presently reside in the other state.

N.C.G.S. § 50A-203 (2019). Here, it is undisputed that the second part of this test was

met when the trial court made unchallenged findings that Laurie’s mother,

respondent-father, and Laurie no longer resided in Delaware when DSS filed the

juvenile petition. However, respondent-father argues that the trial court did not

satisfy the first part of the test because it did not have jurisdiction to make an initial

child-custody determination under N.C.G.S. § 50A-201(a).

-4- IN RE L.T.

Section 50A-201(a)(1) states that North Carolina courts have jurisdiction to

make an initial custody determination if North Carolina is the “home state” of the

child when the proceedings commence. The UCCJEA defines “home state” as “the

state in which a child lived with a parent or a person acting as a parent for at least

six consecutive months immediately before the commencement of a child-custody

proceeding.” N.C.G.S. § 50A-102(7) (2019).

Respondent-father argues that North Carolina was not Laurie’s home state at

the time DSS filed the neglect and dependency petition. His argument relies

primarily on the following finding from the trial court’s 12 June 2017 order continuing

adjudication of the juvenile petition:

2. Prior to the hearing, the GAL Attorney Advocate and the attorney for the Father voiced concerns regarding jurisdiction of the Court in this matter.

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Related

In re T.J.D.W. & J.J.W.
653 S.E.2d 143 (Supreme Court of North Carolina, 2007)
In re K.J.L.
677 S.E.2d 835 (Supreme Court of North Carolina, 2009)
In re T.J.D.W.
642 S.E.2d 471 (Court of Appeals of North Carolina, 2007)

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