In re A.K.D., 745 S.E.2d 7

Petitioner petitioned to terminate Respondent's parental rights to the juveniles, alleging failure to pay support, neglect, and abandonment.
Trial hearings occurred in 2012; orders terminated Respondent's parental rights based on a stipulation that willful abandonment existed for six months pre-petition.
The trial court expressly relied on a stipulation concluding abandonment and total grounds under N.C. Gen. Stat. § 7B-1111(7).
Respondent appealed, challenging the validity of the adjudicatory stipulation invoked to support termination.
Court reversed and remanded for new adjudicatory hearing, because the stipulation did not establish willful abandonment; dispositional issues were not decided on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the adjudicatory termination ground was validly established	Respondent argues the stipulation did not prove willful abandonment.	Petitioner contends the stipulation to abandonment suffices for adjudicatory grounds.	Stipulation invalid for legal conclusion; reversal and remand.

In re Blackburn, 142 N.C. App. 607, 543 S.E.2d 906 (2001) (two-step juvenile-termination review framework; standards for adjudicatory findings)
In re C.C., 173 N.C. App. 375, 618 S.E.2d 813 (2005) (appellate review of factual findings in TPR cases)
Thomas v. Poole, 54 N.C. App. 239, 282 S.E.2d 515 (1981) (stipulations as judicial admissions; binding effect on admitted facts)
In re I.S., 170 N.C. App. 78, 611 S.E.2d 467 (2005) (interpretation of stipulations and factual adequacy)
State v. Prush, 185 N.C. App. 472, 648 S.E.2d 556 (2007) (limitations on stipulations as to matters of law)
In re Adoption of Searle, 82 N.C. App. 273, 346 S.E.2d 511 (1986) (definition of abandonment and willfulness in TPR context)