Hill v. Hill (North Carolina 2018)
A trial court must be clear about its process in imputing income. The father appealed the court order that denied his request for a modification of child support and found him in contempt. The father was terminated from his high-income job and requested a modification in support. The father was unemployed for almost four years before finding a job at about half of his earlier salary. Even though father had no regular income, the trial court imputed income to father for the four years and denied his request to modify. The father appealed. The Court of Appeals remanded the case for additional findings. It found the trial court wasn’t clear as to the time periods for which it was imputing income and how it calculated the amount to impute.