Supreme Court of North Carolina
In re L.L.
December 13, 2024
Summary
The court held that the trial court's permanency-planning order contained sufficient findings to satisfy the relevant statutory requirements governing consideration of reunification, relative placement, and other permanency factors. The trial court could omit written findings for statutory criteria that were irrelevant or uncontested, and it could rely on findings incorporated from a report when those findings demonstrated the parent's progress, cooperation, and availability. The court reversed the Court of Appeals and affirmed the custody order awarding custody to the foster parents and converting the matter to a civil custody proceeding.