The state’s second-highest court has vacated a ruling in a civil dispute over post-separation and divorce child support entered early last year by Alamance County district court judge Meredith Edwards.
The N.C. Court of Appeals has also remanded the case to Alamance County for the entry of findings to accurately depict the “reasonable needs” of the child at the center of the case.
Edwards had entered an order in February 2025 denying retroactive child support for the plaintiff, Devonda Snipes, whose daughter is identified in the case background by the pseudonym “Emily.” (The Appeals Court customarily withholds the names of parties who are minor children.)
On appeal, Snipes, the plaintiff, argued that Edwards had not made the required findings for the child’s needs in order to compare the actual needs to what was being provided for the child at the time.
The Appeals Court agreed.
The child’s father, defendant Alonzo Crisp, who is employed with the town of Chapel Hill and plays piano for his church, has covered the following expenses for Emily: health and dental insurance; uncovered healthcare expenses; a portion of her tuition for Burlington Christian Academy (the paternal grandmother pays $1,696 in tuition, while the remaining $6,722 in tuition is covered by a state-funded “Opportunity Scholarship); clothing; transportation to and from school; meals; daycare costs; and other expenses.
The couple married in 2021, separated in 2022, and finalized their divorce in late June 2022.
Crisp has paid most of the child’s expenses, even though nothing in the June 2022 separation agreement with Snipes required him to do so, according to the case background. The couple’s separation agreement also didn’t specify a custody/visitation schedule, and each parent has had primary custody of Emily every other weekend since their divorce was finalized.
Snipes testified at a hearing in January 2025 that she suffers from multiple sclerosis, for which she receives approximately $1,800 per month in Social Security disability benefits, described as the “only income available to her” since her MS diagnosis in 2015.
Snipes eventually contacted Alamance County child support enforcement and served Crisp with a complaint for child support in November 2023, according to the case background. “In his answer, [Crisp] referenced the agreement, which resulted in Alamance County dismissing the complaint.”
Snipes filed another complaint in April 2024 for “retroactive and prospective child support” payments from Crisp, alleging that Emily’s father made no financial contributions toward his daughter’s expenses.
In her February 2025 order in the case, Edwards concluded that the current custody arrangement and financial agreement, though not required under the separation agreement, was sufficient to cover the costs for Emily’s healthcare, education, and “maintenance,” the case background states.
Citing two earlier state appellate opinions, judge Michael Stading noted in his opinion issued Wednesday for the Court of Appeals, “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,” in keeping with a 2002 opinion.
“Under this standard of review,” the subsequent 2005 opinion stated, “the trial court’s ruling will be overturned only upon a showing that it was so arbitrary that it could not have been the result of a reasoned decision.”
However, the district or superior court judge must make sufficient findings of fact and conclusions of law to demonstrate that the judgment and underlying conclusions represent “a correct application of the law,” Stading noted.
“Examining a child’s reasonable needs” requires the district or superior court judge to consider the child’s health, education, and maintenance, “having due regard to the estates, earnings, conditions, accustomed standard of living of the child and the parties, the child care and homemaker contributions of each party, and [other factors],” according to Stading’s opinion for the Appeals Court.
Stading pointed to a 1963 precedent by the N.C. Supreme Court that there is a presumption that, if two parties agree upon an amount of child support, that amount is presumed to be “just and reasonable” in the absence of evidence to the contrary.
On appeal, Snipes contended that the “evidence as to the specific costs to meet the child’s needs was incomplete, but to a large extent, was simply not available to [the plaintiff].”
Stading concluded that Snipes’ evidence of her and Crisp’s “relative incomes does not show the child’s specific needs at the time of the hearing” in district court and vacated Edwards’ ruling because there were “insufficient findings to support and accurately depict the child’s reasonable needs,” while leaving it up to the district court judge to determine whether a new evidentiary hearing should be held.
Appeals Court judges John Arrowood and Jefferson Griffin concurred with Stading’s opinion.
Snipes was represented by Graham attorney Kelly Fairman.
Crisp was represented by Gibsonville attorney Daniel S. Bullard.
