In a Decision – L.C. v. J.C., , (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed the Trial Court’s determination because the trial Court did not provide findings of fact or conclusions of law. The Motion for Reconsideration was timely filed on the 20th day.
The court first ruled that the motion was timely as it was filed on the 20th day after the trial court's order. The reconsideration motion was filed on day twenty. Therefore, the judge erred in concluding that the reconsideration motion was procedurally deficient pursuant to Rule 4:49-2.
The court further ruled that remand was necessary because the trial court failed to set forth factual or legal findings in support of its decision. As is evident from the order, the judge provided no reasoning to support his conclusion contrary to Rule 1:7-4, which requires judges to include findings of facts and conclusions of law for each determination they make. Compliance with Rule 1:7-4 is crucial because "[m]eaningful appellate review is inhibited unless the judge sets forth the reasons for his or her opinion"; appellate courts should not be "left to conjecture as to what the judge may have had in mind." Salch v. Salch, 240 N.J. Super. 441, 443 (App. Div. 1990).