Abuse and neglect—visitation—dispositional evidence and factual findings—principles for appellate review—In an abuse and neglect matter involving four biological parents (a mother and three men who each fathered one of her children), the Supreme Court reversed a decision by the Court of Appeals, which after prior remand from the higher court reversed the trial court's dispositional order denying visitation to all but one parent, and remanded the case directly to the trial court for any further proceedings. In doing so, the Supreme Court reiterated the following principles: on appeal, dispositional findings of fact are reviewed for whether they are supported by competent evidence; the Juvenile Code permits trial courts to consider hearsay evidence at disposition hearings; here, the trial court was not required to make specific findings for each parent regarding their parental fitness or any conduct inconsistent with their parental rights before determining whether visitation was in the children's best interest; because the issue of each parent's constitutionally protected parental status was not raised at trial, it could not be addressed on appeal; both the evidence and the unchallenged factual findings supported the trial court's disposition; and the trial court was not required to enter separate factual findings and legal conclusions for each parent before making its disposition. In re A.J.L.H. , No. 35PA21-2 (N.C. Jun. 28, 2024) (Author: Justice Tamara Barringer)

North Carolina—direct constitutional claims—condemnation of plaintiffs' properties—adequate state law remedy—In an action raising direct claims under the state constitution ("Corum claims"), in which plaintiffs alleged that defendant city violated their rights to equal protection and substantive due process by condemning plaintiffs' properties and marking them for demolition, the trial court had subject matter jurisdiction to hear the claims even though plaintiffs had not exhausted their administrative remedies first. Exhaustion of administrative remedies does not dictate a court's jurisdiction over direct constitutional claims, but instead speaks to an element of this type of claim: whether an adequate state law remedy exists for the constitutional harm alleged. Further, in determining the availability of an adequate state law remedy, plaintiffs' equal protection and due process claims could not be lumped together, since each claim involved different constitutional rights, raised different injuries, and envisioned different modes of relief. Askew v. City of Kinston , No. 55A23 (N.C. Jun. 28, 2024) (Author: Justice Anita Earls)