In re J.C., 236 N.C. App. 568

DSS filed neglect/dependency petitions (June 27, 2013) based on parental conflict and respondent-mother fabricating sexual-abuse reports against the father; juveniles were adjudicated neglected and dependent and placed with paternal grandmother.
Trial court ordered supervised visitation for respondent at a visitation center at her expense; respondent appealed those orders and this Court previously affirmed the adjudication and disposition.
A permanency-planning hearing (Nov. 13, 2013) resulted in the court changing the permanent plan to reunification with the father, ordering DSS to cease reunification efforts with respondent, and announcing that visitation would be supervised by DSS until a replacement supervisor was found.
The written permanency order (Dec. 12, 2013) mirrored the court’s custody and cessation-of-reunification rulings but instead ordered respondent’s visits to continue at a visitation center at her expense, contradicting the oral pronouncement.
Respondent appealed, challenging subject-matter jurisdiction (UCCJEA findings), the sufficiency of findings supporting cessation of reunification, and the visitation terms and costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction under UCCJEA	Trial court lacked specific jurisdictional findings given prior Kentucky case	Trial court’s assertion of jurisdiction plus evidence of NC residency sufficed; prior appeal controls	Court had subject-matter jurisdiction; argument overruled
Cessation of reunification with mother	Findings and evidence insufficient to show reunification would be futile or harmful	Trial court made written findings (failure to progress, missed visits, lack of cooperation) supported by social worker testimony	Findings supported cessation; affirmed
Authority to require mother to pay supervised-visit costs	Trial court lacked authority to impose visitation costs on respondent	Trial court may set visitation conditions in juveniles’ best interest; prior appellate decision upheld this	Court restated authority exists (consistent with prior decision)
Conflict between oral pronouncement and written order on who supervises visits	Written order conflicts with oral ruling; written order controls and must reflect bench ruling	(No successful defense)	Visitation portion vacated and remanded for written order consistent with oral disposition

In re C.M., 183 N.C. App. 207 (N.C. Ct. App.) (standard for reviewing orders that cease reunification efforts)
In re Robinson, 151 N.C. App. 733 (N.C. Ct. App.) (definition of abuse of discretion)
In re Whisnant, 71 N.C. App. 439 (N.C. Ct. App.) (trial court resolves conflicting witness testimony; appellate deference)
Abels v. Renfro Corp., 126 N.C. App. 800 (N.C. Ct. App.) (entry vs. rendition of judgment; written order controls)
Edwards v. Taylor, 182 N.C. App. 722 (N.C. Ct. App.) (written judgment that generally conforms to oral judgment is valid)
State v. Sellers, 155 N.C. App. 51 (N.C. Ct. App.) (transcript dispositive when written order contradicts oral ruling)
State v. Veazey, 191 N.C. App. 181 (N.C. Ct. App.) (duty of judge and counsel to ensure written order reflects bench rulings)
In re J.V. & M.V., 198 N.C. App. 108 (N.C. Ct. App.) (appealability of orders that change legal custody)