Denial of motion to set aside entry of default; abuse of discretion standard; findings of fact required for award of attorneys' fees under Section 44A-35

adjudication of neglect; North Carolina General Statutes Section 7B-101(15); children placed in WCHS custody; impairment or substantial risk of impairment at the time of adjudication; voluntary safety plan; clear, cogent, and convincing evidence; trial court's findings of fact support its conclusion of law

constitutional procedural due process argument dismissed for failure to preserve, N.C. R. App. P. 10(a); challenges to permanency planning order dismissed as moot.

Juvenile Delinquency; Fatal Defect; Ineffective Assistance of Counsel; Concession of Guilt

appeal of unamended permanency planning order was properly before the Court despite the trial court's entry of an amended order on the same day appeal was noticed from unamended order; trial court order ceasing reunification efforts contained sufficient findings; denying visitation to respondent-mother did not constitute an abused of discretion

DSS, department of social services, juvenile, delinquent, adjudication, disposition, risk assessment, mental health, needs assessment, mental health services director, developmental disability, referral, PTSD, statutory mandate

NCGS 7B-911; Subject-matter jurisdiction

Rule 12(b)(6), motion to dismiss, mental disorder, involuntary commitment, ordinary negligence, gross negligence, qualified immunity, professional judgment, release, kill

Equitable distribution; insufficient findings of fact to support unequal distribution; trial court must find that equal distribution is not equitable before ordering unequal distribution

defendant's actions were not a proximate cause of injuries; no error in granting summary judgment when there was no material issue of fact as to proximate cause