In re: R.L.

CourtCourt of Appeals of North Carolina
DecidedJune 3, 2026
Docket25-466
StatusPublished
AuthorJudge Donna Stroud

This text of In re: R.L. (In re: R.L.) 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: R.L., (N.C. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-466

Filed 3 June 2026

Craven County, No. 22JA000015-240

IN THE MATTER OF: R.L.

Appeal by respondent-mother from order entered 4 December 2024 by Judge

Debra L. Massie in District Court, Craven County. Heard in the Court of Appeals 11

March 2026.

Craven County Department of Social Services, by James D. Dill, for petitioner- appellee Craven County Department of Social Services.

Troutman Pepper Locke LLP, by Joshua D. Davey, for guardian ad litem.

Jeffrey L. Miller for respondent-appellant-mother.

STROUD, Judge.

Respondent Mother challenges an initial disposition and permanency planning

order, arguing that the trial court erred by taking judicial notice of a Responsible

Individuals List (RIL) order and by ceasing efforts to reunify the child with Mother.

Because she did not object to the trial court taking judicial notice of the RIL order,

Mother waived review of this issue. Further, we conclude the trial court did not err

in ceasing reasonable efforts toward reunification. We therefore affirm.

I. Procedural Background

On 15 February 2022, Craven County Department of Social Services (DSS) IN RE: R.L.

Opinion of the Court

filed a juvenile petition on behalf of Robbie,1 contending he was an abused, neglected,

and dependent juvenile. Robbie was three months old and had bruises, a skeletal

survey that revealed previous breaks and injuries, and a broken arm that did not

match the parents’ explanation. On 18 April 2022, DSS filed an amended juvenile

petition still alleging abuse, neglect, and dependency. The hearing on adjudication

was held on 18 and 19 September and 10 October 2023, and the trial court entered

an order adjudicating Robbie as an abused juvenile on 18 January 2024.2

In 2022, both parents filed petitions for judicial review after finding out they

were to be placed on the RIL. On 10 October 2023, at the end of the adjudication

hearing, the court considered the judicial review petitions; it took both the

adjudication and the RIL petition under advisement. On 18 January 2024, the trial

court entered an adjudication order and the RIL orders.

The trial court held a disposition and permanency planning hearing on 30

January and 12 and 26 July 2024, and on 4 December 2024, entered a combined

disposition and permanency planning order (Order), determining that reunification

efforts were not required. On 27 December 2024, Mother timely appealed the

adjudication order3 and the Order.

1 A stipulated pseudonym is used to protect the identity of the child. See N.C. R. App. P. 42.

2 Robbie was also adjudicated neglected, but this is not at issue on appeal.

3 Mother makes no arguments regarding the adjudication order.

-2- IN RE: R.L.

II. RIL Orders

Because Mother is challenging the trial court’s judicial notice of the RIL orders

as part of the factual basis for its determination that “aggravating circumstances”

exist under North Carolina General Statute Section 7B-901, we begin with Mother’s

second issue on appeal: “The trial court erred in taking judicial notice of RIL [o]rders

for purposes of making its factual findings and conclusions in its . . . Order.” Mother

contends that the trial court should not have relied on the RIL orders in any manner

for purposes of the disposition or permanency planning hearing.

At the beginning of the hearing, DSS asked for the trial court to take judicial

notice of the adjudication order entered on 18 January 2024 and the “two orders filed

in 22 JRI 10,” which were also filed on 18 January 2024. The “two orders” were the

RIL orders. Neither Mother nor Father made any objection to judicial notice of the

orders. The trial court stated that it would take judicial notice. Mother’s counsel

asked whether the court was also taking “judicial notice of the court report or

anything we haven’t got to that point.” The trial court clarified that it was taking

notice of only “the orders,” and Mother’s counsel—confirming, “The RIL orders”—

stated he had “[n]o objection.”

In In re L.N.H, our Supreme Court held that the respondent-mother who failed

to object to the trial court’s taking judicial notice of medical records previously

admitted at another hearing in the case “waive[d] appellate review of the issue.” 382

N.C. 536, 541, 879 S.E.2d 138, 142–43 (2022) (citation omitted). Because Mother

-3- IN RE: R.L.

raised no objection to the trial court’s judicial notice of the RIL orders here, she has

likewise waived appellate review.

III. Cessation of Reunification

We begin our analysis of Mother’s next issue by clarifying what she is not

arguing. She claims that “[t]he trial court erred in ceasing/eliminating reunification

as a permanent plan at the consolidated initial disposition/permanency planning,”

because “the relevant evidence was insufficient to support the necessary findings, and

the relevant findings were insufficient to support a conclusion, that aggravating

circumstances existed.” Mother thus does not challenge the trial court’s abuse

adjudication. To the contrary, she acknowledges that “[d]espite her actual innocence,

[she] must concede the supported findings in adjudication as adequate to conclude

Robbie’s status as an abused . . . juvenile based on the inference of circumstances

occurring between 17 January 2022 and 5 February 2022.”

Nor does Mother challenge the permanency planning portion of the Order.

Finding of fact 82 states that the trial court “has found aggravating circumstances

for the Initial Dispositional portion of these hearings and reasonable efforts at

reunification are no longer required for purposes of the Permanency Planning and

Review portion of th[is] hearing.” In other words, we need not reach ceasing

reunification as to the permanency planning portion of the Order

Because Mother’s challenge to ceasing reunification rests on the dispositional

finding of aggravated circumstances, we need not address ceasing reunification as to

-4- IN RE: R.L.

the Order’s permanency planning portion. We thus review the trial court’s decision

to cease reunification efforts only under the Order’s initial disposition portion.

North Carolina General Statute Section 7B-901 sets out the aggravating

circumstances under which a trial court may make a determination that reasonable

efforts will not be made for reunification in an initial disposition order. N.C. Gen.

Stat. § 7B-901 (2023).

Section 7B-901 provides in pertinent part,

(c) If the disposition order places a juvenile in the custody of a county department of social services, the court shall direct that reasonable efforts for reunification as defined in G.S. 7B-101 shall not be required if the court makes written findings of fact pertaining to any of the following, unless the court concludes that there is compelling evidence warranting continued reunification efforts:

(1) A court of competent jurisdiction determines or has determined that aggravated circumstances exist because the parent has committed or encouraged the commission of, or allowed the continuation of, any of the following upon the juvenile:

....

b. Chronic physical or emotional abuse.

f. Any other act, practice, or conduct that increased the enormity or added to the injurious consequences of the abuse or neglect.

N.C. Gen.

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Related

Woodard v. Mordecai
67 S.E.2d 639 (Supreme Court of North Carolina, 1951)
Kelly v. Kelly
747 S.E.2d 268 (Court of Appeals of North Carolina, 2013)

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In re: R.L., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-rl-ncctapp-2026.