Servatius v. Ryals (North Carolina 2018)

Evidence must support a contempt finding, and the order must then contain the specific findings. The mother filed a motion for order to show cause, alleging that the father had failed to pay support. The court issued the order and ordered the father to appear. After hearing, the trial court declined to hold father in contempt, finding neither party had provided evidence regarding the amount of support father had paid and the total amount owed. The mother appealed. The appellate court found it couldn’t review the trial court’s decision and remanded the case for further findings. It found the order was missing findings and that the record on appeal was incomplete.