In re L.C.: Affirming the “Natural Reasoning” Standard for Neglect Adjudications

Introduction

In In re L.C., 383 N.C. __ (May 23, 2025), the Supreme Court of North Carolina clarified the level of factual specificity required in juvenile neglect adjudications. The case arose from a district‐court order declaring two-year-old “Layla” (referred to by the pseudonym L.C.) a neglected juvenile based on her mother’s longstanding substance abuse, unsafe home environment, and repeated violations of a safety plan. After the Court of Appeals vacated and remanded the adjudication for more granular findings regarding how the mother’s conduct impaired or risked impairing the child, the State and guardian ad litem sought discretionary review. The Supreme Court reversed, holding that the trial court’s detailed factual findings— viewed in their totality and under a “natural reasoning” standard—were sufficient to support a conclusion of neglect without a separate, explicit finding of “substantial risk of impairment.”

Summary of the Judgment

The Supreme Court began by reiterating the statutory definition of a neglected juvenile under N.C.G.S. § 7B-101(15): a child whose parent “does not provide proper care, supervision, or discipline” or who lives in an injurious environment. It observed that North Carolina case law adds a requirement of actual or substantially likely physical, mental, or emotional impairment, but that no specific written finding of “substantial risk of impairment” is mandated. Instead, the trial court’s evidentiary findings must be “sufficient to support its conclusions of law” and allow a reasonable reader to see, by “natural reasoning,” that neglect occurred.

In L.C., the district court found: the mother’s positive drug tests at childbirth; her admission to heavy methamphetamine, heroin, benzodiazepine and alcohol use; a home riddled with rats (or perceived rats); unsupervised access to needles; refusal to cooperate in drug testing; violation of a safety plan within days of signing it; and erratic, threatening behavior toward DSS personnel and family. Viewing those facts taken together, the Supreme Court held that no further explicit finding of “substantial risk of impairment” was required. The Court of Appeals’ contrary demand for more granular findings was reversed, and the adjudication reinstated.

Analysis

Precedents Cited

In re G.C., 384 N.C. 62 (2023) – Held that while trial courts need not include a specific written finding of “substantial risk of impairment,” their findings must support a neglect conclusion by logical inference (“natural reasoning”).
In re Stumbo, 357 N.C. 279 (2003) – Although abuse requires express risk-of-serious-injury findings, neglect definitions differ and do not compel a verbatim “risk” finding when other factual findings suffice to demonstrate impairment or risk thereof.
In re K.S., 380 N.C. 60 (2022), and In re T.M.L., 377 N.C. 369 (2021) – Reiterated deference to factual findings supported by clear, cogent, and convincing evidence and clarified review standards (de novo for conclusions of law).
Various Court of Appeals decisions (e.g., In re A.H.D., In re K.J.B.) – Emphasized that appellate courts will not presume unmade findings; nevertheless, those cases are overruled to the extent they require express findings of “substantial risk of impairment.”

Legal Reasoning

The Supreme Court applied a two-step framework:

Factual Findings Review: Are the trial court’s findings supported by clear, cogent, and convincing evidence? Absent a party’s objection, findings are binding on appeal.
Conclusions of Law Review: Under de novo review, do those findings support the legal conclusion of neglect? This requires no rote repetition of statutory words, but rather that the findings, when viewed as a whole, allow a reasonable observer to conclude that the child suffered—or faced a substantial risk of suffering—physical, mental, or emotional impairment.

The Court emphasized legislative text: unlike the definition of “abuse,” which expressly requires “substantial risk” language, the neglect statute omits that phrasing. The “natural reasoning” standard thus ensures clarity and appellate reviewability without imposing form over substance.

Impact on Future Cases

Trial courts should:

Continue to make comprehensive, narrative factual findings detailing the child’s living conditions, caretaker conduct, and any impairments or risks;
Remember that an explicit finding of “substantial risk of impairment” is not mandatory in neglect proceedings, provided the record as a whole points logically to neglect;
Use headings or numbering to group findings, but focus on substance—documenting events, observations, violations of safety plans, and expert or lay testimony that demonstrate risk or harm;
Make credibility rulings where witness statements are contested, though admissions against interest (e.g., a parent’s confession to using illicit drugs) may be accepted as true without elaboration.

On appeal, courts will uphold neglect adjudications so long as the factual narrative permits “natural reasoning” to the legal conclusion, reinforcing judicial economy and protecting children without undue technicality.

Complex Concepts Simplified

De Novo Review: Appellate courts reconsider legal conclusions fresh, though they accept uncontested findings of fact.
Findings of Fact vs. Conclusions of Law: Findings describe “what happened” (e.g., mother tested positive for drugs at birth). Conclusions say “what it means” legally (e.g., the mother’s environment denied proper supervision and created an injurious setting).
Natural Reasoning Standard: Rather than check every statutory box word-for-word, ask whether a reasonable person reading the trial court’s findings would inevitably see that neglect occurred.
Neglect vs. Abuse Definitions: “Abuse” requires express findings of substantial risk of serious physical injury. “Neglect” focuses on lack of proper care or injurious environment plus impairment or risk thereof—but no verbatim “risk” finding is required if the facts show it.

Conclusion

In re L.C. confirms that North Carolina’s neglect adjudication standard balances rigor with practicality. Trial courts must produce detailed factual findings, but they are not shackled by an obligation to label every risk-oriented fact with statutory jargon. As long as the evidentiary narrative, read in full, demonstrates that a parent’s conduct deprived a child of proper care or exposed the child to an injurious living environment—and that the child suffered or faced a reasonable likelihood of impairment—neglect conclusions will stand. This decision streamlines juvenile neglect proceedings, reinforces judicial clarity, and ensures that the focus remains on protecting vulnerable children rather than parsing formulaic language.