Appellate Court Can’t Review Denial of Motion to Compel Arbitration When Trial Court Fails to State Basis for Their Decision

A trial court that denies a motion to compel arbitration must state the basis for their decision so that an appellate court can properly review the decision, the North Carolina Court of Appeals held.

In Steffes v. DeLapp, No. COA05-864, 2006 WL 1526128 (N.C. Ct. App. June 6, 2006), DeLapp moved to compel arbitration of a dispute between the parties. The trial court denied the motion but gave no grounds for its decision.

The Court held that appellate courts are unable to conduct a meaningful review of a trial court’s decision to deny a motion to compel arbitration without findings of fact or conclusions of law that give reasons for denying the motion.