In re: J.S.C.Â, 253 N.C. App. 291

Seven‑month‑old "Jonah" was hospitalized with two brain bleeds and a possible skull fracture; treating physicians concluded injuries were non‑accidental and consistent with high‑impact trauma.
Parents could not account for the severity of the injuries; both were criminally charged; mother pled guilty to felony child abuse by gross negligent omission and received active prison time.
DSS filed a juvenile petition alleging abuse and neglect; parties executed a consent adjudication order stipulating facts that Jonah was abused and neglected and that medical care had been delayed.
The consent adjudication order was entered pursuant to N.C. Gen. Stat. § 7B‑801(b1) without an adjudicatory hearing; parties reserved rights to present evidence at disposition.
At disposition the trial court kept Jonah in DSS custody, ceased reunification efforts, and limited parents to supervised visitation; mother appealed only the adjudication order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a consent adjudication order must state the "clear and convincing" evidentiary standard	Mother argued, relying on In re Church, that the court erred by not stating the clear and convincing standard required by § 7B‑805	County argued the adjudication was by consent under § 7B‑801(b1), entered on stipulated facts without an adjudicatory hearing, so the § 7B‑805 hearing‑standard requirement did not apply	Court held no reversible error: consent adjudication based on stipulations does not involve an adjudicatory hearing, so the court had no occasion to apply or state the clear and convincing standard; affirmed the orders

In re Church, 136 N.C. App. 654, 525 S.E.2d 478 (N.C. Ct. App.) (required trial court to state evidentiary standard after adjudicatory hearing terminating parental rights)
In re E.N.S., 164 N.C. App. 146, 595 S.E.2d 167 (N.C. Ct. App.) (applied Church principle to initial adjudication proceedings)
In re I.S., 170 N.C. App. 78, 611 S.E.2d 467 (N.C. Ct. App.) (stipulations are judicial admissions and binding)
In re Gleisner, 141 N.C. App. 475, 539 S.E.2d 362 (N.C. Ct. App.) (describing the fact‑finding role of the trial court at adjudicatory hearings)
In re K.P., N.C. App. , 790 S.E.2d 744 (N.C. Ct. App.) (distinguishing adjudicatory hearings from consent adjudications under § 7B‑801(b1))