State v. O'Connor, 222 N.C. App. 235 (Aug. 7, 2012)

In granting the defendant’s motion to suppress, the trial judge erred by failing to make findings of fact resolving material conflicts in the evidence. The court rejected the defendant’s argument that the trial court “indirectly provided a rationale from the bench” by stating that the motion was granted for the reasons in the defendant’s memorandum.