The Lake Norman Brief
Family Law
Plain-English guides to North Carolina family law, including custody, divorce, child support, alimony, property division and protective orders, written by attorney Christopher Adkins.
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Lowery v. Vickers: Grandparent Custody and the Limits of an Immediate Appeal
Parental constitutional rights are fundamental, but invoking them does not automatically make every preliminary custody ruling immediately appealable. Lowery v. Vickers dismissed…
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Randall v. Randall: A Custody Order Needs Evidence and a Fair Hearing
Eighty-one findings cannot replace an evidentiary hearing. Randall v. Randall vacated a permanent custody and support order because the record did not…
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Kerr v. Jensen: Custody Modification, Children’s Interviews, and Appellate Prejudice
Kerr v. Jensen upheld joint legal custody and equal parenting time based on findings about changed circumstances and the children’s welfare. It…
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Kuhlman v. Tapp: Unwanted Contact, Online Harassment, and a Protective Order
Chapter 50B can address fear of continued harassment causing substantial emotional distress even without threatened physical injury. Kuhlman v. Tapp affirmed a…
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Sheena v. Sheena: Why a $110,000 Fee Award Did Not Make an Immediate Appeal Available
A large attorney-fee award does not by itself establish a right to immediate appellate review. This September 2026 Sheena decision dismissed an…
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Johnson v. Johnson: Business Distributions, Goodwill, and Actual Income for Alimony
Business valuation and alimony ask related but distinct questions. Johnson v. Johnson required accounting for business distributions, reconsideration of goodwill under a…
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Mueller v. Loftus: Rule 11 Sanctions After a No-Contact Case Is Dismissed
Voluntary dismissal does not necessarily end a collateral sanctions issue. Mueller v. Loftus affirmed $3,640 in Rule 11 fees based on improper…
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Harkley v. Harkley: Valuation Dates, Divorce Findings, and a Missed Appeal
Harkley v. Harkley addresses evidence from the wrong valuation date and a notice that failed to identify the order being appealed. Discovery…
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Facey v. Facey: Business Expenses, Bitcoin, and the Evidence Needed in Divorce
Facey v. Facey illustrates why support and property division require separate financial analyses. The court upheld adjustments to a business owner’s income…
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Parente v. Texeira: What a Relocation Order Must Explain About a Child’s Welfare
A better job, a larger home, and a new marriage can matter in a relocation case. But a custody order must explain…