In 2015, the North Carolina Supreme Court interpreted for the first time the definition of "caretaker" as provided in the State's Juvenile Code. The court narrowed the definition, providing that the statutory language "an adult relative entrusted with the juvenile's care" means an adult relative who has "a significant degree of parental-type responsibility for the child. " The court's interpretation has made caretaker equivalent to in loco parentis, which results in a heightened standard that likely was not intended by the legislature. This Comment discusses the far-reaching effects of the court's decision on North Carolina's child welfare services, law enforcement, and practitioners who represent or interact with these agencies. This Comment also explores solutions to bridge the widening gap in service provision to the families and children of North Carolina.
Jordan M. Spanner, In Re R.R.N.: Redefining "Caretaker" for North Carolina Child Protective Services, 40 Campbell L. Rev. 265 (2018).