Mecklenburg Cnty. v. Pressley

CourtCourt of Appeals of North Carolina
DecidedDecember 17, 2024
Docket24-328
StatusPublished

This text of Mecklenburg Cnty. v. Pressley (Mecklenburg Cnty. v. Pressley) 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
Mecklenburg Cnty. v. Pressley, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-328

Filed 17 December 2024

Mecklenburg County, No. 19CVD23473

MECKLENBURG COUNTY, O/B/O, SHANNON HERRON, Plaintiff, v.

KEDRIC R. PRESSLEY, Defendant.

Appeal by defendant from order entered 14 September 2023 by Judge Dennis

J. Redwing in Mecklenburg County District Court. Heard in the Court of Appeals 22

October 2024.

Myers Law Firm, PLLC, by Matthew R. Myers, for defendant-appellant.

Cavanaugh Hamrick & McCarthy, PLLC, by Brandon T. McCarthy, for plaintiff-appellee.

FLOOD, Judge.

Defendant Kedric R. Pressley appeals from the trial court’s order modifying

his child support payment. On appeal, Defendant argues the trial court abused its

discretion in modifying the amount of child support without making sufficient

findings of fact. Upon review, we agree and conclude the trial court’s order is not

supported by sufficient findings of fact regarding depreciation expenses. Accordingly,

we reverse and remand for further findings of fact.

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Opinion of the Court

I. Factual and Procedural Background

Defendant and Sharon Herron (“Plaintiff”) are the parents of two minor

children, both born in 2011. Defendant and Plaintiff were never married. Defendant

is a self-employed dump truck owner and operator.

In 2019, the trial court entered an order requiring Defendant to pay $50.00 per

month in child support. Several years later, in 2022, Plaintiff filed a motion for

modification of child support and for attorney’s fees.

The trial court heard Plaintiff’s motion on 16 August 2023. At the hearing,

Plaintiff introduced Defendant’s tax returns for 2021 and 2022, wherein Defendant

claimed depreciation deductions regarding his business expenses on Schedule C of

his personal tax returns. The trial court determined that it would consider

Defendant’s tax returns for the purposes of establishing income, but it would “not

accept[]” the depreciation expenses. The depreciation expenses were thus added back

to Defendant’s gross receipts, which resulted in Defendant’s gross monthly income

being set at $4,783.83. The trial court thereafter ordered Defendant to pay $905.35

per month in child support.

Defendant timely appealed to this Court.

II. Jurisdiction

This Court has jurisdiction to review a final order from a district court

pursuant to N.C. Gen. Stat. § 7A-27(b) (2023).

III. Standard of Review

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“Child support orders entered by a trial court are accorded substantial

deference by appellate courts and our review is limited to a determination of whether

there was a clear abuse of discretion.” Head v. Mosier, 197 N.C. App. 328, 332, 677

S.E.2d 191, 195 (2009) (citation omitted). “The standard of review for findings made

by a trial court sitting without a jury is whether any competent evidence exists in the

record to support said findings.” Row v. Row, 185 N.C. App. 450, 460, 650 S.E.2d 1,

7 (2007) (citation and internal quotation marks omitted). The trial court is required

to “make findings of those specific facts which support its ultimate disposition of the

case . . . to allow a reviewing court to determine from the record whether the judgment

and the legal conclusions which underlie it represent a correct application of the law.”

Coble v. Coble, 300 N.C. 708, 712, 268 S.E.2d 185, 189 (1980).

Additionally, “the trial court must articulate its rationale with sufficient

specificity to facilitate effective appellate review.” Craven Cnty. ex rel v. Hageb, 277

N.C. App. 586, 591, 861 S.E.2d 571, 575 (2021) (citation omitted) (remanding where

the trial court’s findings on the defendant’s income, including the defendant’s

depreciation expenses, were “more conclusory than explanatory” and “offer[ed] us no

basis for review of the trial court’s application of the law to the evidence presented”).

IV. Analysis

On appeal, Defendant argues Findings of Fact 22, 25, 26, 27, and 29 are not

supported by competent evidence, and thus, the trial court abused its discretion in

modifying the amount of child support. Specifically, Defendant contends the trial

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court failed to “make the required distinctions between straight-line and accelerated

depreciation deductions as required” when calculating Defendant’s income, and

therefore the challenged findings are not supported by competent evidence. While

we disagree the trial court must make findings as to any required distinctions

between straight-line and accelerated depreciation deductions, we agree that the trial

court abused its discretion, as its findings are not supported by competent evidence.

“This Court has established that child support obligations are ordinarily

determined by a party’s actual income at the time the order is made or modified.”

Holland v. Holland, 169 N.C. App. 564, 568, 610 S.E.2d 231, 234 (2005) (citation and

internal quotation marks omitted). Under the North Carolina Child Support

Guidelines, child support obligations are “based upon net income converted to gross

annual income[.]” N.C. Child Support Guidelines, Income (1) (2023). The Guidelines

state that income “means a parent’s actual gross income from any source, including

but not limited to income from employment or self-employment (salaries, wages,

commissions, bonuses, dividends, severance pay, etc.), ownership or operation of a

business[.]” N.C. Child Support Guidelines, Income (1). The Guidelines further

provide:

Gross income from self-employment . . . is defined as gross receipts minus ordinary and necessary expenses required for self-employment or business operation. Ordinary and necessary business expenses do not include amounts allowable by the Internal Revenue Service for the accelerated component of depreciation expenses, investment tax credits, or any other business expenses determined by

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the court to be inappropriate for determining gross income. In general, income and expenses from self-employment or operation of a business should be carefully reviewed to determine an appropriate level of gross income available to the parent to satisfy a child support obligation. In most cases, this amount will differ from a determination of business income for tax purposes.

N.C. Child Support Guidelines, Income (2) (2023) (emphasis added).

In Lawrence v. Tise, we considered whether the trial court properly treated

depreciation expenses from the defendant’s income per the Guidelines when setting

a child support order. 107 N.C. App. 140, 147, 419 S.E.2d 176, 181 (1992). In

Lawrence, the trial court “did not consider any depreciation in computing [the]

defendant’s rental property losses”; it did, however, determine “the amount of

depreciation claimed by [the] defendant on his income tax returns, but [the record

was] not clear whether the [trial] court considered the depreciation in computing

defendant’s monthly gross income.” Id. at 148, 419 S.E.2d at 181.

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Related

Holland v. Holland
610 S.E.2d 231 (Court of Appeals of North Carolina, 2005)
Coble v. Coble
268 S.E.2d 185 (Supreme Court of North Carolina, 1980)
Head v. Mosier
677 S.E.2d 191 (Court of Appeals of North Carolina, 2009)
Row v. Row
650 S.E.2d 1 (Court of Appeals of North Carolina, 2007)
Cauble v. Cauble
515 S.E.2d 708 (Court of Appeals of North Carolina, 1999)
Lawrence v. Tise
419 S.E.2d 176 (Court of Appeals of North Carolina, 1992)
Berry v. Berry
809 S.E.2d 908 (Court of Appeals of North Carolina, 2018)

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Mecklenburg Cnty. v. Pressley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mecklenburg-cnty-v-pressley-ncctapp-2024.