Parental Rights – Case Law Wire

North Carolina Family Law Juvenile Law Parental Rights

North Carolina Court of Appeals

In re: J.Q. — Trial Court Lacked Authority to Cease Reunification Efforts at Review Hearing; Permanency Planning Hearing Required

/ June 20, 2026

The North Carolina Court of Appeals vacated an order ceasing a mother’s reunification efforts because the trial court entered that order at a review hearing rather than a permanency planning hearing, holding that N.C.G.S. § 7B-906.1(d1) does not authorize courts to cease reunification at review hearings—that authority belongs exclusively to permanency planning hearings under § 7B-906.2(b)—while also cautioning that missed 30-day permanency planning hearing deadlines must be challenged by writ of mandamus, not appeal.

North Carolina Civil Rights Constitutional Parental Rights

North Carolina Court of Appeals

Uncategorized

Happel v. Guilford Cnty. Bd. of Educ. — Private Medical Society Sufficiently Alleged as State Actor for Corum Claim After Unwanted COVID Vaccine

/ June 20, 2026

A divided North Carolina Court of Appeals held on remand that a private medical society that administered a COVID-19 vaccine to a fourteen-year-old over his objection and without parental consent was sufficiently alleged to be a state actor for a Corum constitutional claim, and that the PREP Act’s complete bar on tort remedies itself satisfies the “no adequate state remedy” element required to bring a direct claim under the North Carolina Constitution.

North Carolina Civil Rights Constitutional Parental Rights

North Carolina Court of Appeals

Uncategorized

Happel v. Guilford County Board of Education — State Constitutional Claims Over Unconsented COVID Vaccine Survive PREP Act; Medical Non-Profit Adequately Alleged as State Actor

/ June 19, 2026

On remand from the North Carolina Supreme Court, the Court of Appeals held that Plaintiffs’ state constitutional claims arising from an unconsented COVID-19 vaccination administered to a minor at a school-based clinic may proceed: the private medical non-profit operating the clinic was adequately alleged to be a state actor under a joint-engagement theory, and the PREP Act’s immunity over tort claims leaves no adequate state remedy, satisfying all elements of a Corum claim.