Faircloth v. Faircloth

CourtCourt of Appeals of North Carolina
DecidedOctober 15, 2025
Docket25-189
StatusUnpublished

This text of Faircloth v. Faircloth (Faircloth v. Faircloth) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Faircloth v. Faircloth, (N.C. Ct. App. 2025).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-189

Filed 15 October 2025

Wake County, No. 23CV000996-910

BRYAN FAIRCLOTH, Plaintiff,

v.

AMANDA FAIRCLOTH, Defendant.

Appeal by defendant from order entered 11 October 2024 by Judge Damian

McCullers in Wake County District Court. Heard in the Court of Appeals

25 September 2025.

No brief filed for Bryan Faircloth, pro se, plaintiff-appellee.

Bosquez Porter Family Law, by Emily C. Jeske, for defendant-appellant.

ARROWOOD, Judge.

Amanda Faircloth (“mother”) appeals from an order granting her and Bryan

Faircloth (“father”) joint physical and legal custody of their two minor children. For

the following reasons, we vacate the trial court’s order and remand for further written

findings of fact.

I. Background FAIRCLOTH V. FAIRCLOTH

Opinion of the Court

Mother and father separated on 27 July 2022 and divorced on

12 September 2023. They share two minor children. Father filed a complaint for

child custody on 26 January 2023. A temporary order for child custody was entered

by consent on 10 May 2023. The temporary order granted joint legal custody to

mother and father and primary physical custody to mother. On 18 March 2024, the

trial court determined that this matter was “high-conflict” and appointed a parenting

coordinator to assist in facilitating the custody order. The matter went to trial on

19 August 2024.

At trial, mother presented evidence of father’s history of domestic violence

during and after their marriage. For example, mother testified that on several

occasions, father threatened to hurt her, including one instance shortly after their

separation where father stated that he was going to “gut” her. Additionally, mother

testified about an incident on 12 September 2022 in which father confronted mother

when she visited their former marital home to retrieve personal items. Mother stated

that while at the home, father grabbed her by the throat and screamed at her. As a

result of the 12 September incident, father pled guilty to a charge of assault on a

female and mother was granted a domestic violence protective order (“DVPO”).

Mother also testified about father’s lack of compliance with previous court

orders. For example, mother stated that despite an order instructing father not to

change any utilities out of mother’s name, he removed mother’s name from the power

four times. Mother further expressed concern about father’s admitted violation of the

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DVPO. The appointed parenting coordinator also provided trial testimony about

father’s compliance and understanding of previous court orders. He stated that

father was frequently confused about what was in the court orders but would follow

directives once corrected.

On 11 October 2024, the trial court issued its permanent child custody order

with the following relevant findings of fact:

9. The Court finds that this is a high conflict case. .... 12. Both of the minor children are generally healthy. 13. Plaintiff is currently employed at John Deere and testified that he has a reasonably flexible work schedule. 14. Defendant is currently employed as a bar manager at Brickhouse Bar and has recently engaged new employment at Pinpoint Raleigh. Defendant testified that she has a reasonably flexible work schedule. 15. Both parties have been involved in the lives of the minor children since their births. 16. Both parties love the minor children and have extended family who love the minor children. 17. Both parties are fit and proper persons to have the custodial roles assigned as set forth below in the decretal paragraphs below. 18. The parties are able to comply with this Order as set forth hereafter.

The omitted findings of fact recounted the procedural history of the case, established

the trial court’s jurisdiction, and described the age and school enrollment of the minor

children. Based on these findings, the trial court concluded that both parties were fit

to have custody of the children and that it was in the best interest of the children for

both parents to have custody. Accordingly, the trial court awarded joint legal and

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physical custody of the children to mother and father. Mother filed a Notice of Appeal

to this Court on 26 November 2024.

II. Discussion

Mother raises three issues on appeal: 1) whether the trial court violated a

statutory mandate in failing to make any findings of fact regarding evidence

presented of domestic violence between the parties; 2) whether the evidence

presented at trial supports the trial court’s findings of fact, and whether those

findings of fact support its conclusions of law and the award of joint legal and physical

custody; and 3) whether the trial court erred in determining that the legal and

physical custody arrangement it ordered was in the best interest of the minor

children. We address each issue below.

A. Standard of Review

The standard of review for challenges to a child custody order is abuse of

discretion. Efstathiadis v. Efstathiadis, 296 N.C. App. 605, 607 (2024). “[T]he trial

court’s findings of fact are conclusive on appeal if supported by substantial evidence,

even if there is sufficient evidence to support contrary findings.” Peters v. Pennington,

210 N.C. App. 1, 12–13 (2011). “Substantial evidence is such relevant evidence as a

reasonable mind might accept as adequate to support a conclusion.” Id. (citing State

v. Smith, 300 N.C. 71, 78–79 (1980)).

B. Domestic Violence

Mother contends the trial court erred in failing to make findings of fact about

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the evidence presented about the history of domestic violence between the parties.

Generally, when awarding custody of a minor child, the guiding standard for

trial courts is the welfare and best interest of the child. Rosero v. Blake, 357 N.C.

193, 207 (2003); see also N.C.G.S. § 50-13.2 (2025). In determining what custody

arrangement is in the best interest of the child, “the court shall consider all relevant

factors including acts of domestic violence between the parties.” N.C.G.S. § 50-

13.2(a). Furthermore, “[a]n order for custody must include written findings of fact

that reflect the consideration of each of these factors and that support the

determination of what is in the best interest of the child.” Id. Where trial courts

have failed to make critical findings of fact, this Court has vacated the custody order

and remanded the matter for the trial court to make written findings of fact. See

Aguilar v. Mayen, 293 N.C. App. 474, 482–83 (2024).

Here, mother presented evidence of a history of domestic violence between the

parties through her testimony recounting specific instances of threats and violence,

the DVPO against father, and father’s conviction for assault on a female. However,

the trial court made no written findings of fact that reflected consideration of the

history of domestic violence or how its consideration supported its determination of

the best interests of the children.

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Related

State v. Smith
265 S.E.2d 164 (Supreme Court of North Carolina, 1980)
Rosero v. Blake
581 S.E.2d 41 (Supreme Court of North Carolina, 2003)
State v. Sparks
657 S.E.2d 655 (Supreme Court of North Carolina, 2008)
Peters v. Pennington
707 S.E.2d 724 (Court of Appeals of North Carolina, 2011)
In re A.P.
812 S.E.2d 840 (Supreme Court of North Carolina, 2018)

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Bluebook (online)
Faircloth v. Faircloth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faircloth-v-faircloth-ncctapp-2025.