Crews v. Paysour (North Carolina 2018)

On remand, a trial court may consider new evidence in a child support hearing. If it doesn’t, the findings of fact and conclusions of law in the order must be based on the existing record. The appellate court remanded the initial order in this case for further findings. During the hearing on remand, the trial court didn’t hear any additional evidence. The mother appealed the new order. She argued that since the trial court didn’t hear any new evidence, any findings as to events after the initial hearing weren’t supported by evidence. She also argued that the order didn’t address all of her claims and contained mathematical errors. The Appellate Court remanded the order for the second time. It didn’t rule on the substance of the arguments because it found the trial court may have not correctly understood the legal standard for child support in high income cases. It agreed with the mother that the order contained mathematical errors and didn’t address all of her claims.