The North Carolina Supreme Court issued an opinion Dec. 12 reversing a Court of Appeals decision that had applied the doctrine of collateral estoppel to bar a juvenile petition in *In re A.D.H.* The court remanded the case to the trial court for further proceedings after finding the appeals court erred in its legal analysis.
Justice Barringer, writing for the court, stated that the case required the justices to "decide whether the Court of Appeals erred by holding the juvenile petition at issue was barred by the doctrine of collateral estoppel." After examining the doctrine more closely, the court concluded the appeals court had incorrectly applied the legal principle.
The case centers on A.D.H., a minor child born to unmarried parents on June 17, 2013. The parents lived together with the child from birth until they separated in 2018. In February 2021, the mother filed a complaint seeking primary custody of the child, with the father receiving secondary placement rights.
The Carteret County District Court initially entered a temporary child custody order granting joint legal custody to both parents, with the mother receiving primary physical custody. However, the case evolved to involve the Carteret County Department of Social Services, leading to the juvenile petition that became the subject of the Supreme Court's review.
The Court of Appeals had previously issued a unanimous decision in 2024, reported at 295 N.C. App. 480, that vacated and remanded an order entered Sept. 19, 2022, by Judge W. David McFadyen III in Carteret County District Court. The appeals court applied collateral estoppel, a legal doctrine that prevents parties from relitigating issues that have already been decided in previous proceedings.
Collateral estoppel, also known as issue preclusion, typically applies when the same issue was actually litigated and determined in a prior proceeding between the same parties, and that determination was essential to the judgment. The doctrine serves to promote judicial efficiency and prevent inconsistent verdicts by barring repetitive litigation of settled issues.
However, the Supreme Court found that the Court of Appeals had misapplied this doctrine in the juvenile context. Justice Barringer noted that the court needed to bring "our collateral estoppel doctrine into sharper focus" before concluding that the appeals court had erred.
The case attracted significant attention from legal organizations statewide. The North Carolina Association of Social Services Attorneys filed an amicus curiae brief, represented by attorneys Marc S. Gentile, Jason Hicks, Melissa Livesay, Mary Holliday, Mona Leipold, Rachael Hawes, and Brian Godfrey. The North Carolina Department of Health and Human Services also participated as amicus curiae, with representation from Attorney General Jeff Jackson's office, including Solicitor General Nicholas S. Brod and Assistant Attorneys General Andrew L. Hayes and Maria B. Lattimore.
The petitioner-appellant Carteret County Department of Social Services was represented by Carolina Law Group attorney Kirby H. Smith III. The Guardian ad Litem was represented by Matthew D. Wunsche, while the father was represented by attorneys Sundee G. Stephenson and Bradley N. Schulz. Notably, no brief was filed for the mother in the proceedings.
The Supreme Court heard oral arguments in the case on Oct. 28, 2025, before issuing its decision approximately six weeks later. The case proceeded to the state's highest court through discretionary review under N.C.G.S. § 7A-31, which allows the Supreme Court to review selected Court of Appeals decisions.
The involvement of multiple amicus parties suggests the case has broader implications for child welfare proceedings across North Carolina. Social services attorneys and the state's health and human services department likely viewed the case as establishing important precedent for how collateral estoppel applies in juvenile matters.
Juvenile proceedings often involve complex fact patterns where the same parties may appear in multiple proceedings over time as circumstances change. The application of collateral estoppel in such contexts requires careful consideration of whether previous determinations should bar future petitions aimed at protecting children's welfare.
The Supreme Court's reversal indicates that courts must exercise particular caution when applying issue preclusion doctrines in child welfare cases, where the primary consideration is the best interests of the child rather than traditional litigation efficiency concerns.
With the case now remanded to the trial court, proceedings will continue in Carteret County District Court. The trial court will need to address the juvenile petition without the collateral estoppel bar that the Court of Appeals had imposed.
The decision clarifies the boundaries of collateral estoppel in North Carolina's juvenile justice system and provides guidance for social services departments, courts, and attorneys handling similar cases throughout the state. The ruling ensures that child protection proceedings can move forward when circumstances warrant, even when previous litigation has occurred between the same parties.