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By Ed Boltz, 15 October, 2025

N.C. Ct. App.: Pelc v. Pham – Contempt Vacated; Execution, Not Incarceration, Required for Enforcement of Money Judgment

Summary:

In Pelc v. Pham (No. COA25-27, filed Oct. 15, 2025), the North Carolina Court of Appeals (Tyson, J.) vacated a Mecklenburg County contempt order imprisoning a former spouse for failure to pay a contractual debt arising from a Form I-864 “Affidavit of Support” and related loan. The appellate court held that the trial court lacked jurisdiction to use contempt powers to enforce a money judgment grounded in breach of contract.

By Ed Boltz, 1 October, 2025

N.C. Ct. of Appeals: Irish Creek HOA v. Rogers - Foreclosure Set Aside as Covid-Era Service was Insufficient

Summary:

Trenita Rogers bought her Winterville home in 2010, subject to the Irish Creek HOA. In 2021, after allegedly failing to pay $1,391.23 in assessments, the HOA filed liens and moved forward with foreclosure. Notice was attempted by certified mail during the USPS’s Covid-19 “contactless” protocol—where carriers often signed “C19” themselves instead of obtaining the addressee’s signature—and by sheriff posting without a proper court order.

By Ed Boltz, 13 June, 2025

N.C. Ct. App.: Pelc v. Pham – Contempt Vacated; Execution, Not Incarceration, Required for Enforcement of Money Judgment

N.C. Ct. of Appeals: Irish Creek HOA v. Rogers - Foreclosure Set Aside as Covid-Era Service was Insufficient

Summary:

N.C. Ct. of App.: Palmetto RTC v. Fielden- Slander of Title and Lis Pendens

N.C. Ct. of App.: Fine Line Homes v. Luthera- Materialman's Lien Invalid due to Absent Date in Claim of Lien

N.C. Ct. of App.: Paradigm Park Holdings v. Global Growth Holdings

N.C. Ct. of Appeals: Midland Credit Management v. Mitchell- Procedural Errors Lead to Dismissal of Pro Se Consumer Case

NC Ct. of App.: In re Godfrey- Ratification of Forged Mortgage

N.C. Ct. of Appeals: East Bay v. Baxley- No Tolling of Statute of Limitations for Judgment Renewal

N.C. Ct. of App.: Anhui Omi Vinyl v. USA Opel Flooring- Fraudulent Conveyance under State Law

N.C. Ct. of App.: Adventure Trail of Cherokee v. Owens-Parole Evidence for Lease