Eidson v. Kakouras (North Carolina 2022)

Stipulations to facts are favored but they must be clearly shown in the record and both parties must agree. The parents divorced in 2012 and post-divorce actions for modification of custody and child support began immediately. Specific to this appeal, the father appeals the latest child support order, which resolved a variety of outstanding motions. The appellate court vacated the orders on appeal and remanded. The trial court erred in relying on an undocumented stipulation between the parents to use outdated income instead of current income, erred in calculating the parents’ incomes. The appellate court upheld the finding of a substantial change of circumstances to justify the modification.