In Wenninger v. Wenninger, decided May 7, 2024, the North Carolina Court of Appeals held that an equitable distribution judgment was void for lack of a necessary party because the parties in the equitable distribution proceeding stipulated in a pre-trial order that certain items of property were held in a revocable Trust and further stipulated that some of the property held by the Trust was marital property. The court of appeals held that the Trust was a necessary party, even though the trial court refused to distribute the items in the Trust because they were not owned by either party.