Domestic Relations – Civil Practice – Contempt – Attorney’s Fees – Insufficient Findings

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Brownstead v. Brownstead (Lawyers Weekly No. 14-16-0127, 10 pp.) (Robert N. Hunter Jr., J.) Appealed from Mecklenburg County District Court (Paige B. McThenia, J.) N.C. App. Unpub.

Holding: Where the trial court ruled that plaintiff was entitled to attorney’s fees by stating only the bare statutory language that plaintiff had “insufficient means with which to defray the costs of this action,” the findings are insufficient to support an award of attorney’s fees under G.S. § 50-13.6 and Dixon v. Gordon, 734 S.E.2d 299 (2012), review denied, 743 S.E.2d 191 (2013).

We vacate the award of attorney’s fees and remand for further findings. We affirm the order finding defendant in contempt for failure to pay child support.

Because defendant does not cite any relevant legal authority noting that the trial court was prohibited from modifying the prior contempt order in a subsequent contempt order (by correcting the amount of arrearage), we hold defendant has abandoned his argument on appeal by failing to cite authority for his position.