In Solomon v. Solomon, the Supreme Court of Alaska held that a trial court must make sufficient factual findings to allow review of its legal conclusion an individual has a history of domestic violence. Terrace and Wendy Solomon married in 1999 and had four children; the two separated in 2014, and in January 2015 Wendy filed for divorce. Terrace’s attorney had continuous difficulty getting in touch with his client because Terrace had been arrested and was being held by the army. As Terrace could not be contacted on the day of the trial Wendy was the only witness; she testified to violent acts Terrace allegedly committed. The parties agreed Wendy should have sole physical custody but disagreed on whether she should have sole legal custody. Though the superior court did not specify the particular facts supporting its determination, it concluded that Terrace had a history of domestic violence based on Wendy’s description of multiple incidents of low-level domestic violence. This conclusion triggered a presumption that Terrace could not have any form of custody of the children that could only be rebutted if he complied with the mandates of section 25.24.150(h) of the Alaska Statutes. On this basis the court awarded sole legal custody to Wendy. Terrace appealed arguing the superior court had made insufficient findings to support its conclusion. The Supreme Court of Alaska agreed and held a “superior court must make its findings with sufficient specificity” to allow a higher court to “review both the grounds for its decision and its application of the law to the facts.” The supreme court reasoned that for proper review of the trial court’s decision the record needed enough specificity for the supreme court to determine whether Wendy’s testimony established the elements of a domestic violence crime. The supreme court concluded the record was insufficient as it only said Terrace “went far beyond the minimum threshold of two” crimes. Vacating and remanding for further findings, the supreme court held that a trial court must make sufficient findings to allow an appellate court to review its determination that an individual has a history of domestic violence
 420 P. 3d 1234 (Alaska 2018).