In re: J.K.Â, 253 N.C. App. 57

DSS filed a juvenile petition (9/29/2014) alleging one-year-old Jennifer was neglected/dependent after mother’s hospitalizations, mental-health problems, and positive marijuana test; child was placed with father and paternal grandmother.
Trial court adjudicated the child dependent (8/18/2015) and held a permanency planning hearing (2/17/2016).
On 5/17/2016 the trial court entered (1) a Permanency Planning Order closing the juvenile file, finding reunification with father achieved, directing DSS and GAL to close files, relieving counsel, and awarding custody to father; and (2) a separate two‑page Custody Order granting legal and physical custody to father and supervised visitation to mother.
Mother appealed, arguing (a) the Permanency Planning Order contains contradictory conclusions of law (referring to "the Respondents" rather than the mother) and (b) the Custody Order improperly attempted to create a civil Chapter 50 custody order without terminating juvenile jurisdiction or making the findings required by N.C. Gen. Stat. § 7B‑911.
The Court of Appeals affirmed the Permanency Planning Order but remanded solely to correct clerical errors in two conclusions of law; it reversed and remanded the Custody Order because it failed to follow § 7B‑911’s mandatory transfer/termination requirements and must be reissued in compliance with that statute.

Issue	Mother’s Argument	DSS/GAL (Respondent Father) Argument	Held
Whether contradictory conclusions in the Permanency Planning Order fatally undermine custody award	The Order contains inconsistent conclusions (saying return to "the Respondents" would be contrary to welfare) making review impossible	References to "the Respondents" were clerical/ministerial errors; record shows mother unfit and father fit; custody to father is supported	Court treated the wording as clerical errors, remanded to correct conclusions to refer to "Respondent Mother" only; substantive custody award affirmed
Whether the separate Custody Order properly terminated juvenile jurisdiction and created a civil Chapter 50 custody action under § 7B‑911	Trial court did not make the explicit § 7B‑911 findings or initiate a civil action; custody order is not enforceable/modifiable under Chapter 50 without required findings	Trial court intended to terminate juvenile jurisdiction and transfer custody to father, but failed to follow the statutory procedure	Court reversed and remanded: custody order must be reissued in compliance with § 7B‑911 (make required findings, initiate civil file or direct clerk, designate parties/caption); trial court may hold further hearing at its discretion

In re A.C., 786 S.E.2d 728 (N.C. Ct. App. 2016) (standard of review for permanency planning orders; findings of fact conclusive if supported by competent evidence)
In re D.B., 714 S.E.2d 522 (N.C. Ct. App. 2011) (clerical errors in judgments/orders remanded for correction where record must "speak the truth")
Sherrick v. Sherrick, 704 S.E.2d 314 (N.C. Ct. App. 2011) (discussing § 7B‑911 transfer procedure and that jurisdiction cannot be conferred or bypassed by consent; statutory transfer requirements are mandatory)