N.C. Court of Appeals Issues New Family Law Opinions – April 1, 2026

 

Overview

The North Carolina Court of Appeals has released new opinions addressing jurisdiction under the Uniform Child-Custody Jurisdiction and Enforcement Act (UCCJEA), as well as recurring issues in child support and alimony. These decisions reinforce a familiar appellate theme: trial courts must apply the correct legal framework and support their rulings with competent evidence and precise findings.

While fact-specific, these opinions offer practical guidance for trial courts and family law practitioners handling interstate custody disputes and financial claims.

Bonomo v. Shabat – UCCJEA Jurisdiction Strictly Limits North Carolina Custody Authority

The Court of Appeals reversed a trial court’s refusal to dismiss a custody action for lack of subject matter jurisdiction under the UCCJEA.

The child had lived exclusively in the United Kingdom since birth. The Court held:

  • The UK was the child’s home state

  • North Carolina lacked significant-connection jurisdiction

  • No alternative jurisdictional basis applied

The Court rejected speculative claims about diplomatic immunity.

Why it matters: UCCJEA jurisdiction is strict and evidence-driven. If the child has no meaningful connection to North Carolina, the case will not proceed here.

Chan v. Severn – Financial Orders Must Be Grounded in Competent Evidence

The Court vacated rulings on child support and alimony due to unsupported findings.

Errors included:

  • Incorrect income calculations

  • Unsupported childcare and expense findings

  • Improper use of gross income for alimony

These errors affected both child support and alimony determinations.

Why it matters: Financial orders must be built on accurate, supported data. Even small errors can undermine an entire order on appeal.

Key Takeaways

1. Jurisdiction must be proven, not assumed
2. Findings must resolve disputes, not summarize testimony
3. Financial accuracy is essential

Appellate courts continue to demand disciplined analysis and evidentiary precision.

Conclusion

At Siemens Family Law Group, these decisions reflect the standards we apply every day in our practice. We focus on building cases with clear, credible evidence, applying the correct legal framework, and presenting issues in a way that supports durable, defensible outcomes at both the trial and appellate levels.

Whether addressing jurisdictional challenges, complex financial issues, or high-conflict custody matters, our approach is grounded in precision, preparation, and a deep understanding of how North Carolina courts evaluate family law cases.

If you are navigating a custody, support, or equitable distribution matter and want guidance aligned with current appellate expectations, we are available to help you move forward with clarity and confidence.

 
Siemens Family Law Group