Milligan v. Crews, 279 N.C. App. 371, 2021-NCCOA-493 (Sept. 21, 2021)

The trial court failed to make adequate findings of fact to support its orders denying the plaintiffs’ motions for domestic violation protective orders against the defendant, their biological father’s wife.  The court noted that state supreme court precedent had interpreted N.C. Rule Civ. P. 52(a)(1) to require a trial court to make specific findings of fact and separate conclusions of law when sitting without a jury.  The trial court’s failure to make any findings of fact on form AOC-CV-306, other than who was present at the hearing, precluded the Court of Appeals from conducting a meaningful review of its order denying the motions.