IN RE: G.R. (2026)

Respondent–Mother (Mother) appeals from the trial court's order adjudicating her oldest child, G.R., Jr. (Griffin), an abused and neglected juvenile, adjudicating her three younger children J.R. (John), J.R. (Juniper), and G.R. (Grace)¹ neglected juveniles, ceasing reunification efforts to all four children under N.C.G.S. § 7B-901(c)(2), and ceasing all visitation between Mother and the children under N.C.G.S. § 7B-905.1(a). On appeal, Mother argues that the trial court (1) erred in adjudicating Griffin abused; (2) erred in adjudicating Griffin, John, Juniper, and Grace neglected; (3) erred in ceasing reunification efforts with each of the children; and (4) abused its discretion in abruptly ceasing Mother's visitation. For the reasons that follow, this Court affirms the trial court's order.

I. Background

Mother and Respondent–Father (Father) are married but have been separated since 2022. Together, they are parents of four biological children—Griffin, John, Juniper, and Grace—who are the subjects of this appeal. Mother's history with the child-welfare system spans more than a decade and over multiple North Carolina counties. Before the events of the present case, Mother had two older children, T.G. (Taj) and T.G. (Trinitee), who were the subject of custody-determination proceedings in Forsyth County.²

Between 2021 and January 2025, the Orange County Department of Social Services (OCDSS) and the Forsyth County Department of Social Services provided in-home services to Mother, Father, and the four juveniles in a series of cases addressing Mother's diagnosed bipolar disorder, housing instability, and inappropriate physical discipline. In August 2023, the family was evicted and briefly entered a shelter before the family was removed from the shelter due to Mother's dysregulated behavior. Mother and the children then returned to the apartment and squatted there for the next eleven months until they obtained new housing in July 2024.

In May 2024, Griffin and John asserted to OCDSS Mother had struck them with a cord; Griffin further alleged Mother had “choked” him with two hands such that he “could not talk or breathe.” OCDSS substantiated for unsafe discipline. On 1 August 2024, OCDSS received a report asserting mother had threatened to punch Griffin in the face and to place him in foster care. Griffin denied the allegations when interviewed at home, and the report was listed as unsubstantiated. The in-home services case was closed in January 2025 based on Mother's engagement with and participation in recommended therapeutic services.

On 8 April 2025, OCDSS received a report asserting Griffin had jumped out of a third-story window and Mother had struck Griffin's bicycle with her car while Griffin was riding it to prevent him from leaving their home without permission. Five-year-old John and two-year-old Juniper were inside the car at the time. Mother admitted the incidents to the assigned social worker, Jocelyn Peacock. During the social worker's visit, Mother entered a safety plan and agreed to engage Griffin in appropriate mental-health services.

Between 8 April and 30 April 2025, Griffin left home without permission on at least four separate occasions and was returned by law enforcement officers each time. When Ms. Peacock questioned Mother about Griffin's allegation about being choked and about the children's repeated departures from the home, Mother became escalated and aggressive. Griffin had a psychiatric appointment scheduled for the following day; despite apprehension due to Mother's behavior, Ms. Peacock agreed to provide transportation. When she arrived the next morning, Griffin had again run away. Mother refused to meet with OCDSS mobile crisis unit, and the appointment was missed. Similar additional incidents occurred on 30 April 2025 in the presence of Chapel Hill Police officers.

On 30 April 2025, OCDSS filed juvenile petitions alleging Griffin, John, Juniper, and Grace to be neglected juveniles under N.C.G.S. § 7B-101(15)(2025). The trial court granted OCDSS nonsecure custody of Griffin, John, and Juniper that same day. By the time OCDSS executed the nonsecure custody orders, Mother had already locked Griffin out of the home and told him he would “never see her or his siblings again.”

On 1 May 2025, Ms. Peacock observed two loop-pattern marks on Griffin's arm. That same day, Mother was criminally charged with two counts of misdemeanor child abuse and seven counts of contributing to the delinquency of a minor. During post-removal supervised visitation, Mother became verbally aggressive towards Griffin and escalated conduct with OCDSS staff. Because of Griffin's injuries and disclosures, Ms. Peacock requested and obtained court orders for Child Medical Evaluations (CMEs) of Griffin, John, and Juniper.

Understanding Mother was nine months pregnant with Grace, OCDSS attempted to engage her in planning for Grace's care after birth. Mother refused to engage in planning and stated that social workers would not be allowed at the hospital. On 30 May 2025, Mother gave birth to Grace at UNC Children's hospital. On 2 June 2025, OCDSS filed a juvenile petition alleging Grace to be a neglected juvenile under N.C.G.S. § 7B-101(15) (2025) and obtained nonsecure custody prior to her leaving the hospital. The trial court placed Grace with her maternal aunt, Griffin in a licensed therapeutic foster home, and John and Juniper together in a separate licensed foster home.

Between May and June 2025, Griffin, John, and Juniper underwent additional CMEs at the Duke Child Abuse and Neglect Medical Evaluation Clinic. During Griffin's diagnostic interview, he asserted he had jumped from the window to flee Mother, Mother had beaten and choked him and whipped him with a cord, and he “did not want to live” anymore. Griffin was later diagnosed with PTSD and ADHD; Ms. Lewter identified “significant concerns” about starting trauma-focused therapy while Griffin continued visits with Mother because his PTSD symptoms were a “protective factor for him.” John's CME corroborated these accounts. The CMEs of John and Juniper concluded that both juveniles were neglected.

Dr. Kristy Matala, Ph.D., conducted a Parental Capacity Evaluation of Mother. At trial, Dr. Matala testified to diagnosing Mother with Bipolar I Disorder, Borderline Personality Disorder, and unspecified trauma and stressor-related disorders. She further testified to Mother's history of medication and treatment noncompliance, antisocial behavior, compulsiveness and rigidity in thinking, and lack of personal responsibility. Dr. Matala concluded that Mother's capacity to parent was “extremely low” and that reunification was “extremely risky.”

The trial court conducted multiple adjudicatory and dispositional hearings between 18 September and 20 November 2025. On 6 November 2025, the trial court orally adjudicated Griffin as an abused and neglected juvenile and John, Juniper, and Grace as neglected juveniles. On 12 December 2025, the trial court orally rendered its dispositional ruling, ceasing reunification efforts under N.C.G.S. § 7B-901(c)(2) and eliminating Mother's visitation with the juveniles under N.C.G.S. § 7B-905.1(a).

On 8 January 2026, the trial court formalized its oral dispositions in a written order. It entered numerous findings of fact; among them, Mother's lengthy history of CPS involvement with the Forsyth, Mecklenburg, and Guilford County DSS agencies prior to 2022, including prior substantiations of physical abuse and neglect (FoFs #22, #24–#25); the juveniles’ exposure to domestic violence in the home, Griffin's vehicle impact, and her demonstrable “emotional dysregulation and aggressive behavior” toward all parties (FoF #68); and Mother's “extremely low” parental capacity more generally (FoFs #82–84, #87); Mother challenges certain portions of these findings on appeal.

Based on those findings, the trial court concluded as a matter of law that “Griffin [wa]s an abused juvenile” under N.C.G.S. § 7B-101(1), that he, “John, Juniper, and Grace [we]re ․ [n]eglected [j]uveniles” under N.C.G.S. § 7B-101(15), that “no[ ] compelling evidence warrant[s] continued reunification efforts with Mother,” and that “[v]isitation between [Mother] and the juveniles” would be “contrary to the juveniles’ best interests.” The order relieved OCDSS of reasonable reunification efforts as to Mother under N.C.G.S. § 7B-901(c)(2), ceased Mother's visitation with each of the children under N.C.G.S. § 7B-905.1(a), and continued custody and placement authority with OCDSS. N.C.G.S. §§ 7B-901(c)(2); 905.1(a)(2025), Mother timely filed notice of appeal.

II. Jurisdiction

This Court has jurisdiction over Mother's appeal from the trial court's initial adjudication and disposition orders under N.C.G.S. §§ 7B-1001(a)(3), 7A-27(b)(2). See N.C.G.S. § 7B-1001(a)(3) (2025) (appeal of right from initial order of disposition and source adjudication order); id. § 7A-27(b)(2).

III. Analysis

Mother argues that the trial court (1) erred in adjudicating Griffin abused; (2) erred in adjudicating Griffin, John, Juniper, and Grace neglected; (3) erred in ceasing reunification efforts with each of the children; and (4) abused its discretion in abruptly ceasing Mother's visitation. Because the trial court's neglect adjudications and dispositions independently sustain its 8 January 2026 order, we do not reach Mother's separate challenge to Griffin's abuse adjudication. See id. § 7B-901(c)(2).

When reviewing an adjudication order, both unchallenged findings and those challenged findings supported by “clear and convincing evidence,” N.C.G.S. § 7B-805, bind us “even in the face of evidence to the contrary,” In re R.B., 280 N.C. 424, 430 (2021); see In re T.N.H., 372 N.C. 403, 407 (2019). But whether the sustained findings support a conclusion of neglect under N.C.G.S. § 7B-101(15) is a question of law reviewed de novo. See In re K.W., 282 N.C. App. 283, 286 (2022). We further review the trial court's discontinuance of reunification efforts and assessment of the juveniles’ best interests only for an abuse of discretion, see In re C.M., 183 N.C. App. 207, 213 (2007), “manifestly unsupported by reason,” In re T.A.M., 378 N.C. 64, 71 (2021) (quotation omitted).

A. Challenged Findings

Mother challenges several of the trial court's findings of fact. We need not resolve most of these challenges because the trial court's unchallenged findings independently support the trial court's conclusions of law, neglect adjudications, cessation of reunification efforts, and cessation of visitation. T.N.H., 372 N.C. at 407; see Koufman v. Koufman, 330 N.C. 93, 97 (1991). However, we briefly address two of Mother's finding challenges.

First, Mother argues that FoF #68(e)—that Mother had “hit [Griffin] with her car while he rode his bike”—impermissibly contradicts the trial court's oral rendition that it would not find that Mother had “struck [Griffin] with the car.” See In re J.C., 236 N.C. App. 558, 562 (2014) (transcript controls where written order conflicts with oral rendition). Presuming, without deciding, FoF #68(e) is impermissible to the extent it uses the word hit, Mother's own admission in FoF #27(c) that her vehicle contacted Griffin's bicycle, while John and Juniper were passengers, supports the injurious-environment determination.

Second, Mother argues that FoFs #22, #24–#25 rest at least in part on inadmissible hearsay drawn from out-of-county DSS records.³ Presuming without deciding these historical findings should be disregarded, the trial court's unchallenged findings regarding Mother's admissions, the social worker's observations, the CMEs, and Dr. Matala's testimony independently support each neglect adjudication and each dispositional determination. See C.M., 183 N.C. App. at 213. We now address below Mother's substantive challenges to each of the trial court's adjudicatory and dispositional determinations.

B. Adjudications

Mother argues that the trial court erred in its adjudication of Griffin, John, Juniper, and Grace as neglected juveniles. We disagree.

A “neglected juvenile” is one whose parent “[d]oes not provide proper care, supervision, or discipline” or “[c]reates or allows to be created a living environment ․ injurious to the juvenile's welfare.” N.C.G.S. § 7B-101(15)(a), (e). The statute makes it “relevant whether that juvenile lives in a home where another juvenile has been subjected to abuse or neglect by an adult who regularly lives in the home.” Id. § 7B-101(15). That statutory factor reaches not only the child's siblings but also the parent's prior history of neglecting them. See In re Ballard, 311 N.C. 708, 715 (1984). Prior terminations involving other children of the parent are further admissible in subsequent proceedings to determine whether that parent has neglected any of the children. See N.C.G.S. § 7B-101(15) (sibling-neglect factor).⁴ Adjudication requires “some physical, mental, or emotional impairment of the juvenile or substantial risk of such impairment.” In re Stumbo, 357 N.C. 279, 283 (2003). “A finding of any one of the enumerated grounds ․ sufficient[ly] ․ support[s]” the adjudication. In re Humphrey, 156 N.C. App. 533, 540 (2003).

The sustained findings satisfy the neglect standard as applied to each juvenile. As to Griffin, his loop-pattern injuries, CME disclosures of beatings, and repeated suicidal ideation establish Mother's provision of improper care and injurious environment. As to John and Juniper, their presence during Griffin's abuse, exposure to Mother's escalated behavior with professionals, and her supervisory failures more generally, establish their respective injurious living environments. Concerning Grace, Mother's disengagement from prenatal appointments and mental-health services, together with the concurrent adjudicated neglect of her siblings in Mother's home, establish Grace's substantial risk of impairment. See In re A.W., 377 N.C. 238, 243 (2021). Mother's reliance on Stumbo, 357 N.C. at 288–89 (single unexplained supervisory lapse), and In re G.B.G., 297 N.C. App. 772, 782 (2025) (abstract exposure to remote domestic violence), does not compel a different result because the sustained findings go well beyond either scenario. See In re J.A.M., 372 N.C. 1, 9 (2019). Thus, we affirm the trial court's adjudications of Griffin, John, Juniper, and Grace as neglected juveniles.

C. Reunification

Next, Mother argues that the trial court erred in ceasing reunification efforts under N.C.G.S. § 7B-901(c)(2025). We disagree.

Under N.C.G.S. § 7B-901(c), the trial court must cease reasonable reunification efforts upon finding any enumerated aggravating circumstance unless it “concludes that ․ compelling evidence warrant[s] continued reunification efforts.” One circumstance relevant here is that a “court of competent jurisdiction has terminated involuntarily the parental rights of the parent to another child of the parent.” N.C.G.S. § 7B-901(c)(2). Mother does not dispute that her parental rights to Taj were involuntarily terminated on 18 December 2015. Whether continued efforts are warranted is within the trial court's sound discretion. C.M., 183 N.C. App. at 213.

The sustained findings support the trial court's determination that no compelling evidence warranted continued reunification efforts. Mother remained disengaged from mental-health services, locked Griffin out of the home while telling him he would never see his siblings again, and displayed continuing verbal aggression at supervised visits. Dr. Matala testified to the ongoing risk of reunification. Read alongside the prior involuntary termination and the adjudicated present-day neglect of Mother's four young children, those findings show that the trial court's conclusion was neither arbitrary nor unreasoned. T.A.M., 378 N.C. at 71. We thus affirm the cessation of reunification.

D. Visitation

Finally, Mother argues the trial court erred in ceasing her visitation rights with the juveniles under N.C.G.S. § 7B-905.1. We disagree here as well.

An order removing custody of a juvenile from a parent must “provide for appropriate visitation as may be in the best interests of the juvenile consistent with the juvenile's health and safety,” and may deny visitation entirely where it would be inconsistent with those interests. N.C.G.S. § 7B-905.1(a)(2025); see In re T.R.T., 225 N.C. App. 567, 573 (2013).

The sustained findings support the trial court's conclusion that visitation would be contrary to the juveniles’ best interests. Griffin's PTSD symptoms are “a protective factor” for him during trauma-focused therapy, and Mother's documented conduct at supervised visits supports the trial court's conclusion that continued visitation would compromise Griffin's protective symptoms and expose all four juveniles to her ongoing emotional dysregulation. Although Mother emphasizes the juveniles’ bonds with her, the guardian ad litem’s recommendation, and Grace's kinship placement with Mother's sister, the trial court was not required to give this evidence undue weight. That decision was neither manifestly unsupported by reason nor so arbitrary that it could not have been the result of a reasoned decision. T.A.M., 378 N.C. at 71. Thus, we affirm the trial court's cessation of visitation.

IV. Conclusion

For the reasons discussed above, this Court affirms the trial court's neglect adjudications, cessation of reunification efforts, and cessation of visitation.

AFFIRMED.

Report per Rule 30(e).

I generally concur with the portions of the majority's opinion which conclude sufficient evidence supports the trial court's adjudications of neglect and ceasing reunification efforts with Mother. I respectfully dissent from the portion of the majority's opinion which holds the trial court did not err by denying Mother all visitation with all four children under N.C. Gen. Stat. § 7B-905.1 (2025). The dispositional order does not reflect the trial court properly considered the best interests of the three younger children. I vote to remand to the trial court for further findings.

“An order that removes custody of a juvenile from a parent, guardian, or custodian or that continues the juvenile's placement outside the home shall provide for visitation that is in the best interests of the juvenile consistent with the juvenile's health and safety, including no visitation.” N.C. Gen. Stat. § 7B-905.1(a) (2025) (emphasis supplied). The assessment of the juvenile's best interests concerning visitation is left to the sound discretion of the trial court and “appellate courts review the trial court's assessment of a juvenile's best interests solely for an abuse of discretion.” In re K.N.L.P., 380 N.C. 756, 759, 869 S.E.2d 643 (2022). “A trial court may be reversed for abuse of discretion only upon a showing that its ruling was so arbitrary that it could not have been the result of a reasoned decision.” In re J.B., 172 N.C. App. 1, 14, 616 S.E.2d 264, 272 (2005) (citation omitted).

At the time of the adjudication and dispositional hearings, Griffin, the oldest child, was eleven years old. John was six years old, Juniper was four years old, and Grace was nearly six months old. The record discloses significant discord between Mother and Griffin, who would continually run away from home and engage in other dangerous behaviors.

The trial court found Mother had physically abused Griffin. Griffin asserted Mother had whipped him with a belt and looped cord and had choked him. The medical findings were consistent with Griffin's accusation of being whipped with a cord. The court further found Mother had emotionally abused Griffin by telling him she did not want him anymore, and Griffin had blamed himself for his mother's actions and stated he did not want to live.

With regard to his siblings, Griffin asserted Mother had hit his brother, John, with a “flip flop”, and his sister, Juniper with her hand. John asserted Mother sometimes “whoops us.” The trial court found the significant CPS history shows a “pattern of [Mother] failing to properly manage her mental health diagnoses to the detriment of the welfare of her children.”

The findings of fact within the dispositional order, which pertain to visitation and support the trial court's denial of Mother's visitation with all four children, are as follows:

87. Despite recent engagement in therapeutic services,

Respondent mother continues to demonstrate emotional regulation in her interaction with professionals and at visitations, including but not limited to, the following:

․

b. Respondent mother has blamed [Griffin] during visits for the foster care case.

c. Respondent mother yelled in [Griffin's] face and [Juniper] hid in the visitation room.

d. Respondent mother attended [Griffin's] dentist appointment and became heightened and angry impacting the dentist ability to provide [Griffin] care.

e. Respondent mother had talked about the case during visits contrary to the agreed-upon rules.

f. Respondent mother has not taken redirection or suggestions from agency staff to assist her in management the juveniles, including [Grace], at visits.

g. Respondent mother has become angry with the social worker and other agency staff, acting in a hostile and aggressive manner.

․

97. [Griffin] completed a CCA which diagnosed him with PTSD and recommended trauma-focused Cognitive Behavioral Therapy (TF-CBT). The evaluator noted significant concerns in starting TF-CBT while [Griffin] was continuing to have visits with Respondent mother as his PTSD symptoms are a protective factor for him.

These findings address whether it is in the best interest of Griffin to continue to have visitation with Mother. Based upon the record and the findings, the trial court's denial of all visitation with Griffin does not rise to the level to constitute an abuse of discretion. See In re J.B., 172 N.C. App. at 14, 616 S.E.2d at 272.

The trial court's order fails to make sufficient findings and supported conclusions of whether it is in the best interests of the other three children to continue to have any, supervised or unsupervised, visitation with Mother. N.C. Gen. Stat. § 7B-905.1(a) (2025). “Although the district court may deny a parent visitation with a child if it determines visitation is not in the child's best interest, ․ the court must make appropriate findings to support an order denying visitation.” In re N.K., 274 N.C. App. 5, 11, 851 S.E.2d 389, 394 (2020).

The dispositional order regarding the other three children is properly remanded to the trial court for additional findings and supported conclusions regarding whether visitation with Mother is in the best interest of John, Juniper, and Grace. Id.; N.C. Gen. Stat. § 7B-905.1(a) (2025).

FOOTNOTES

1.   In accordance with North Carolina Rule of Appellate Procedure 42(b), we refer to the minor children by pseudonyms to protect their identities. See N.C. R. App. P. 42(b).

2.   The 2015 termination followed more than four years of DSS involvement with Mother's two older children (referred to herein as Taj and Trinitee, also pseudonyms) arising from Mother's diagnosed bipolar disorder, intermittent explosive disorder, borderline personality disorder, medication noncompliance, and inappropriate physical discipline. Mother was criminally charged with and convicted of misdemeanor child abuse, and Forsyth County DSS obtained nonsecure custody of both children. In April 2015, Mother's visits with Taj were suspended upon therapeutic recommendation. The grounds for termination included abuse and neglect, likelihood of repetition of neglect, and willful failure to make reasonable progress. The same risk factors reappear throughout the record of the present case.

3.   Although Mother's brief argues there was no foundation for admission of the DSS records from other counties, she did not preserve this issue for review. Mother's brief mixes arguments regarding the proper foundation for admission of DSS records from other counties with arguments regarding hearsay in the records, although she does not direct our attention to the statements in the out-of-county DSS records she contends would be hearsay. At the hearing, Father raised an objection regarding some of the out-of-county DSS records, limiting his objection to the time period before 2021: “[Y]our honor, the basis of my objection is just to contents in this report that are prior to 2021.” Mother then made a motion in limine regarding all of the records from Orange County and other counties based on relevancy under Rules 402, 403, and 404 and hearsay; her motion in limine did not challenge the foundation for admission of the records. We also note that some of the records from other counties were court orders, not DSS reports, and Mother's arguments as to hearsay or foundation would not apply to the court orders.

4.   The trial court was entitled to consider Mother's 2015 involuntary termination as to Taj and the 2022 GCDSS custody of Trinitee as relevant history bearing on the current risk of impairment as to Griffin, John, Juniper, and Grace.

MURRY, Judge.

Judge STROUD concurs. Judge TYSON concurs in part and dissents in part by separate opinion.