Anthony E. Hill v. Christine Strickland

CourtLouisiana Court of Appeal
DecidedJune 12, 2024
Docket2024-CA-0116
StatusPublished

This text of Anthony E. Hill v. Christine Strickland (Anthony E. Hill v. Christine Strickland) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anthony E. Hill v. Christine Strickland, (La. Ct. App. 2024).

Opinion

ANTHONY E. HILL * NO. 2024-CA-0116

VERSUS * COURT OF APPEAL

CHRISTINE STRICKLAND * FOURTH CIRCUIT

* STATE OF LOUISIANA

*******

CONSOLIDATED WITH: CONSOLIDATED WITH:

CHRISTINE M. STRICKLAND NO. 2024-CA-0117

VERSUS

ANTHONY EARL HILL

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2023-10231, DIVISION “H” Honorable Jane E. Booth, Judge Pro Tempore ****** JUDGE SANDRA CABRINA JENKINS ****** (Court composed of Judge Daniel L. Dysart, Judge Sandra Cabrina Jenkins, Judge Dale N. Atkins)

Ashley Potter THE LAW OFFICE OF JAMES A. GRAHAM, LLC 701 Loyola Avenue, Suite 403 New Orleans, LA 70113

COUNSEL FOR PLAINTIFF/APPELLEE

N. Kim Nguyen LAW OFFICE OF N. KIM NGUYEN, LLC 401 Whitney Ave. Suite 515 Gretna, LA 70056

COUNSEL FOR DEFENDANT/APPELLANT

AFFIRMED JUNE 12, 2024 SCJ DLD DNA Appellant, Christine Strickland (“Mrs. Strickland”) appeals the trial court’s

October 20, 2023 judgment granting the protective order and awarding Anthony

Hill (“Mr. Hill”) temporary custody of A.G.H. For the reasons that follow, we

affirm the trial court’s judgment.

FACTUAL AND PROCEDURAL HISTORY

Mrs. Strickland and Mr. Hill are the parents of the minor child, A.G.H. Mrs.

Strickland and Mr. Hill were never married. Pursuant to the January 29, 2021

consent judgment, Mrs. Strickland and Mr. Hill shared joint custody of A.G.H.,

with Mrs. Strickland designated as the domiciliary parent.

Mrs. Strickland filed a motion for emergency temporary custody pursuant to

La. C.C.P. art. 3945 on April 19, 2023, alleging that Mr. Hill advised her that he

would not be returning A.G.H. to her because he had been informed that the child

had been physically disciplined. A few months later, the trial court was notified a

Child-In-Need-of-Care petition (“CINC”) had been filed in the Juvenile Court for

the Parish of Orleans. The trial court issued an ex propio motu order on July 14,

2023, staying the pending matter until the Juvenile Court of the Parish of Orleans

1 relinquishes its exclusive jurisdiction over the matter. Thereafter, the CINC

petition was dismissed.

On August 30, 2023, Mr. Hill filed a petition for protection from abuse

pursuant to La. R.S. 46:2131 et seq, against Mrs. Strickland on behalf of A.G.H.

Mr. Hill alleged that Mrs. Strickland failed to intervene and protect A.G.H. from

the repeated punching in the stomach and chest at least once per week over the

course of a year by Mrs. Strickland’s husband, Jason Strickland (“Mr. Strickland”).

Upon review of the petition, the trial court issued a temporary restraining order

against Mrs. Strickland. Mr. Hill was granted temporary custody of A.G.H, and

Mrs. Strickland was prohibited from contacting or coming within 100 yards of the

minor child.

Mrs. Strickland subsequently filed an expedited motion to transfer the

custody matter to the district court division where the protective order matter was

pending. The trial court ordered the consolidation of the two matters. The trial

court held a show cause hearing on September 21, 2023, and September 22, 2023,

to address the petition for protection from abuse.1 The trial court extended the

temporary restraining order against Mrs. Strickland, and reset the matter for

October 20, 2023 for a show cause hearing. On October 20, 2023, the trial court

granted the protective order for eighteen months, awarding Mr. Hill temporary

custody of A.G.H. and Mrs. Strickland unsupervised visitation with A.G.H. in

Houston, Texas.

Mrs. Strickland now appeals the trial court’s judgment.

1 This matter was tried alongside another petition for protection from abuse filed by Mr. Hill

against Jason Strickland, Anthony E. Hill v. Jason Strickland, Civil District Court Case No. 2022-10232 “H,” which is also before this Court in Anthony E. Hill v. Jason Strickland, 2024- CA-0118.

2 STANDARD OF REVIEW

“An appellate court reviews domestic orders for an abuse of discretion.”

Carrie v. Jones, 2021-0659, p. 4 (La. App. 4 Cir. 1/21/22), 334 So.3d 834, 839

(quoting Patterson v. Charles, 2019-0333, p. 9 (La. App. 4 Cir. 9/11/19), 282

So.3d 1075, 1082). An appellate court may not set aside a trial court’s “finding of

fact in the absence of manifest error or unless it is clearly wrong.” S.L.B. v. C.E.B,

2017-0978, p. 5 (La. App. 4 Cir. 7/27/18), 252 So.3d 956 (quoting Rabalais v.

Nash, 2006-0999, p. 4 (La. 3/9/07), 952 So.2d 653, 657). “The trial court sitting as

trier of fact is in the best position to evaluate the demeanor of the witnesses, and its

credibility determinations will not be disturbed on appeal absent manifest error.”

Patterson, 2019-0333, p. 9, 282 So.3d at 1082 (citing Alfonso v. Cooper, 2014-

0145, pp. 13-14, 146 So.3d 796, 805).

“Child custody decisions are reviewed under abuse of discretion standard.”

Hiatt v. Duhe, 2017-0574, p. 5 (La. App. 4 Cir. 1/31/18), 238 So.3d 484, 488

(citing Leard v. Schenker, 2006-1116, p. 3 (La. 6/16/06), 931 So.2d 355, 357).

“Every child custody case must be viewed based on its own particular facts and the

relationships involved, with the goal of determining the best interests of the child.”

Hiatt, 2017-0574, pp. 5-6, 238 So.3d at 488 (citing Mulkey v. Mulkey, 2012-2709,

p. 15 (La. 5/7/13), 118 So.3d 357, 367). “In most child custody matters, the trial

court’s ruling is based heavily on factual findings.” Bergmann v. Nguyen, 2021-

0553, p. 14 (La. App. 4 Cir. 4/27/22), 366 So.3d 422, 432, writ denied, 2022-

01075 (La. 10/18/22), 348 So.3d 725 (citing Hanks v. Hanks, [20]13-1442, p. 8

(La. App. 4 Cir. 4/16/14), 140 So.3d 208, 214) (alteration in original). An

appellate court may not set aside a trial court’s factual findings absent manifest

3 error. Id. at p. 14, 366 So.3d at 433 (quoting Evans v. Lungrin, 97-0541, [19]97-

0577, p. 6 (La. 2/6/98), 708 So.2d 731, 735) (alteration in original).

DISCUSSION

Mrs. Strickland raises four assignments of error: (1) whether the trial court

erred in basing its ruling on Department of Child and Family Services (“DCFS”)

records obtained through the trial court’s sua sponte issuance of a subpoena duces

tecum that were not properly introduced into evidence; (2) whether the trial court

based its ruling on hearsay testimony of the minor child when the child’s testimony

was never corroborated in a Watermeier hearing or through physical evidence; (3)

whether the trial court erred in allowing the audio recording of Candace Davis

(“Ms. Davis”) into evidence without proper foundation; and (4) whether the trial

court erred in granting the protective order when Mr. Hill did not prove by a

preponderance of the evidence domestic abuse against the minor child.

Authentication of DCFS Records

Mrs. Strickland argues that the trial court improperly allowed the

introduction of DCFS records into evidence due to the lack of authenticity and

accuracy of the documents. Mrs. Strickland further argues that the trial court failed

to consider whether good cause existed for in-chambers testimony of the DCFS

employee who authored the documents in order to clarify the discrepancy of the

number of pages in the DCFS records, and to allow for cross examination by

counsel.

“Authentication of evidence is required in order for evidence to be

admissible at trial.” State in Interest of K.B., 2023-0409, p. 19 (La. App. 4 Cir.

9/26/23), 372 So.3d 864, 878, writ denied, 2023-01421 (La.

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Related

Watermeier v. Watermeier
462 So. 2d 1272 (Louisiana Court of Appeal, 1985)
State v. Cosey
779 So. 2d 675 (Supreme Court of Louisiana, 2000)
Leard v. Schenker
931 So. 2d 355 (Supreme Court of Louisiana, 2006)
Evans v. Lungrin
708 So. 2d 731 (Supreme Court of Louisiana, 1998)
Penn v. Penn
28 So. 3d 304 (Louisiana Court of Appeal, 2009)
Rabalais v. Nash
952 So. 2d 653 (Supreme Court of Louisiana, 2007)
State v. Ashford
878 So. 2d 798 (Louisiana Court of Appeal, 2004)
Bowden v. Brown
114 So. 3d 1194 (Louisiana Court of Appeal, 2013)
Mulkey v. Mulkey
118 So. 3d 357 (Supreme Court of Louisiana, 2013)
State v. Martin
131 So. 3d 121 (Louisiana Court of Appeal, 2013)
Hanks v. Hanks
140 So. 3d 208 (Louisiana Court of Appeal, 2014)
Alfonso v. Cooper
146 So. 3d 796 (Louisiana Court of Appeal, 2014)
State v. Smith
192 So. 3d 836 (Louisiana Court of Appeal, 2016)
Brown v. Chategnier
208 So. 3d 410 (Louisiana Court of Appeal, 2016)
State v. Luckey
212 So. 3d 1220 (Louisiana Court of Appeal, 2017)
State v. Rice
222 So. 3d 32 (Supreme Court of Louisiana, 2017)
Hiatt v. Duhe
238 So. 3d 484 (Louisiana Court of Appeal, 2018)
S.L.B. v. C.E.B.
252 So. 3d 950 (Louisiana Court of Appeal, 2018)

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