In re: Derrick WoodardÂ, 249 N.C. App. 64

Respondent Derrick Woodard was involuntarily committed to UNC Wakebrook for inpatient treatment following a 12 February 2015 hearing.
The commitment order authorized up to 30 days inpatient and 60 days outpatient treatment; Respondent filed a notice of appeal.
There was no verbatim transcript of the hearing because courtroom recording failed and no court reporter was present.
Appellate counsel attempted to reconstruct the record by sending inquiries to witnesses, the judge, counsel, and staff; responses were obtained.
Judge Meyer provided a five-page memorandum detailing testimony and supporting findings of fact, supplemented by notes from counsel and a summary from the State.
The issue on appeal was whether the lack of a transcript deprived Respondent of meaningful appellate review and required a new hearing; the Court affirmed the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does absence of a verbatim transcript require a new hearing?	Woodard argues lack of transcript prejudices review.	Woodard contends reconstruction is insufficient for meaningful review.	No new hearing required; no prejudice shown.
Is the reconstruction of the hearing an adequate substitute for a transcript?	Woodard satisfies reconstruction efforts via judge’s memorandum and notes.	Woodard’s reconstruction mirrors Shackleford’s insufficient alternative.	Yes; reconstruction provided an adequate alternative to a transcript.
Did the reconstruction preserve meaningful appellate review under controlling standards?	Reconstruction allowed review of the order’s factual support.	Without a transcript, review could be limited, but reconstruction suffices here.	Respondent failed to show prejudice; meaningful review preserved.

State v. Hobbs, 190 N.C. App. 183 (2008) (reconstruction of missing testimony by appellate counsel supported by surrounding materials)
State v. Lawrence, 352 N.C. 1 (2000) (absence of complete transcript not prejudicial where alternatives fulfill same function)