In re T.L.S., 817 S.E.2d 798

On May 31, 2016, 12-year-old Christine reported to her teacher, medical staff, and CPS that respondent-father had sexually assaulted her; a rape kit and medical evaluations followed.
Respondent-mother confirmed parts of Christine’s disclosure, entered a safety plan with DSS requiring respondent-father to leave and have no contact, but later allowed contact and did not disclose allegations to Christine’s therapist.
Christine made consistent disclosures to medical and forensic evaluators, described multiple assaults, and exhibited symptoms consistent with sexual and emotional abuse; experts opined she shared characteristics of abused children.
DSS removed Christine, Cynthia, Meghan, and Thomas from the home and filed petitions: Christine was alleged abused, neglected, and dependent; the three siblings were alleged neglected and dependent.
The trial court adjudicated Christine abused and neglected and adjudicated Cynthia, Meghan, and Thomas neglected; DSS retained custody. Respondents appealed challenging the sufficiency of findings for the three siblings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cynthia, Meghan, and Thomas were neglected juveniles under N.C. Gen. Stat. § 7B‑101(15)	DSS: The household environment and parents’ conduct (father’s sexual abuse of Christine, safety‑plan violations, mother’s failure to protect) created an environment injurious to the welfare of all children.	Respondents: Findings do not show those three children suffered impairment or substantial risk of harm, nor that they knew of or were exposed to Christine’s abuse.	Reversed as to Cynthia, Meghan, and Thomas — findings insufficient to show they were neglected.
Whether Christine was an abused and neglected juvenile	DSS: Christine’s disclosures, medical and forensic evaluations, expert testimony, and mother's failures supported abuse and emotional harm findings.	Respondents: (Not contested on appeal in principal briefs)	Affirmed as to Christine — adjudicated abused and neglected; disposition leaving her in DSS custody affirmed.

In re T.H.T., 185 N.C. App. 337 (discussing appellate standards for juvenile adjudication review)
In re J.S.L., 177 N.C. App. 151 (review of conclusions of law de novo in juvenile cases)
In re J.C.B., 233 N.C. App. 641 (trial‑court findings about one child’s abuse did not automatically support neglect adjudication for other children without findings of awareness, impairment, or substantial risk)
Koufman v. Koufman, 330 N.C. 93 (unchallenged factual findings are binding on appeal)
In re Safriet, 112 N.C. App. 747 (neglect requires proof of physical, mental, or emotional impairment or substantial risk from failure to provide proper care)