Ashley Layman v. Richard Lee Bohanon Jr

CourtKentucky Supreme Court
DecidedMarch 26, 2020
Docket2019-SC-0364
StatusUnpublished

This text of Ashley Layman v. Richard Lee Bohanon Jr (Ashley Layman v. Richard Lee Bohanon Jr) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ashley Layman v. Richard Lee Bohanon Jr, (Ky. 2020).

Opinion

RENDERED: MARCH 26, 2020 TO BE PUBLISHED

2019-SC-000364-DGE P ATP slul# ASHLEY LAYMAN APPELLANT

ON REVIEW FROM COURT OF APPEALS V. CASE NO. 2018-CA-001540 BOYD CIRCUIT COURT NO. 16-CI-00255

RICHARD LEE BOHANON, JR. APPELLEE

OPINION OF THE COURT BY JUSTICE KELLER

REVERSING

The Boyd Family Court issued an order modifying the parties’

timesharing arrangement and holiday schedule and recalculating child

support. The father, Richard Lee Bohanon, Jr., appealed. The Court of Appeals

affirmed the family court’s modification of the holiday schedule but reversed

that portion of the family court’s order that modified timesharing and child

support. The mother, Ashley Layman, petitioned this Court for discretionary

review, which we granted. Having reviewed the record and the applicable law,

we reverse the decision of the Court of Appeals as to the issues before us.

I. BACKGROUND

Layman and Bohanon divorced on June 14, 2016. They entered into a

settlement agreement in which they shared joint custody and equal parenting time with their two minor children, then ages four and seven. Under that

agreement, neither parent was listed as the primary residential custodian.

Rather, Layman would keep the children one week and Bohanon would keep

them the following week. This week-on-week-off schedule continued for

approximately two months, until Bohanon’s work schedule changed in August

2016. Under his new schedule, he had two weekdays off each week. As a

result, the parties altered the timesharing arrangement such that the children

stayed with Bohanon two consecutive days during the week (including

overnight) and every other weekend. Under this modified arrangement, the

children stayed with Bohanon on Tuesday and Wednesday of one week, then

Thursday through Sunday of the next week, after which the two-week cycle

would repeat. Thus, the parties still shared equal parenting time.1

The parties’ modified timesharing arrangement was not memorialized in

writing but continued for almost two years. During that time, Bohanon

remarried. He is now a stepfather to his wife’s two children, and he and his

wife also have twins, bom in March 2018. He lives approximately three

minutes from Layman’s home.

On April 13, 2018, Bohanon filed a motion to memorialize the modified

timesharing schedule. He also moved for, among other things,2 modification of

1 Layman testified that the arrangement provided her with slightly more time with the children, but only about four days total, spread out over the course of the year. 2 Bohanon also asked the family court to modify certain provisions of the settlement agreement related to life insurance, health insurance, and unpaid medical

2 the parties’ holiday schedule, arguing that the current schedule allowed

Layman to have the children on almost every holiday. In addition, Bohanon

requested a modification of child support. More specifically, he sought

recalculation of the amount agreed to in the settlement agreement—$400 per

month—because Layman voluntarily quit her previous job and had since been

receiving “gift income” from her parents, including $2,000 a month and a new

automobile.

The family court held a two-day hearing. During the hearing, Layman

requested that the children stay with her Mondays through Fridays. Under her

proposed timesharing schedule, the children would sleep at her house during

the week, but Bohanon could visit with the children and attend extracurricular

activities on his two days off. She argued that this arrangement would be in the

best interest of the children because it would provide consistency and hopefully

help with certain behavioral issues. For example, she testified that the children

struggled to complete their homework during the week, there were issues with

transporting the children to and from their extracurricular activities, and the

parties’ daughter often fought with one of Bohanon’s stepchildren.

On October 3, 2018, the family court entered an order in which it found

that “it is in the best interests of the children for the children to live primarily

with [Layman].” It also ordered that Bohanon’s parenting time follow the

schedule set forth in Plaintiff’s Exhibit # 1, which outlined the timesharing

expenses. He also requested that each party be allowed to claim one child for tax purposes. None of these issues are before us today.

3 schedule that the parties had been abiding by since August 2016. The court

also adopted the holiday and vacation schedule proposed by Layman, and

recalculated Bohanon’s child support at $925 per month based on the

guidelines but eliminated his obligation to pay for extracurricular activities or

academic expenses.3

Bohanon filed a motion to alter, amend, or vacate. Relevant to this

appeal, Bohanon took issue with the court’s designation of Layman as the

primary residential custodian and its calculation of child support. On the issue

of child support, Bohanon again argued that Layman was voluntarily

underemployed and received gifts from her parents that should be included as

income in the child support calculation.

In response, the family court issued an order on October 15, 2018

amending its previous order. The court explained that it had inadvertently

referenced Plaintiffs Exhibit # 1 and clarified that this would not be the

timesharing schedule going forward. Rather, under the amended order,

Bohanon would keep the children every other weekend and two days per week

for three hours each day, from 5:00 PM to 8:00 PM. The family court explained

that this schedule would allow the children to spend time with Bohanon, while

also addressing Layman’s concerns about homework, academics, and

3 The family court order also addressed other matters not relevant for purposes of this appeal, including Bohanon’s request that each party be able to claim one child for tax purposes and his request that the court amend the life insurance provision of the settlement agreement. The court sustained the motion to claim one child for tax purposes but found that it lacked the jurisdiction necessary to amend the life insurance provision. Those rulings are not before this court.

4 extracurricular activities. It would also allow the children to spend the night in

the same home throughout the week.

Bohanon appealed. In his prehearing statement to the Court of Appeals,

Bohanon argued that the family court erred in (1) awarding primary custody to

Layman; (2) reducing Bohanon’s timesharing; and (3) recalculating child

support “without considering all relevant facts and income.” More specifically,

he argued that the family court failed to consider the presumption for joint

custody and equal parenting time set forth in the custody determination

statute, Kentucky Revised Statute (“KRS”) 403.270, and the custody

modification statute, KRS 403.340. He also argued that the family court failed

to consider shared parenting time when calculating child support, and he again

reiterated his argument that Layman was voluntarily underemployed and

receiving gift income.

The Court of Appeals affirmed in part and reversed in part. As explained

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stewart v. Burton
108 S.W.3d 647 (Court of Appeals of Kentucky, 2003)
Downing v. Downing
45 S.W.3d 449 (Court of Appeals of Kentucky, 2001)
Frances v. Frances
266 S.W.3d 754 (Kentucky Supreme Court, 2008)
Pennington v. Marcum
266 S.W.3d 759 (Kentucky Supreme Court, 2008)
Murphy v. Murphy
272 S.W.3d 864 (Court of Appeals of Kentucky, 2008)
Drury v. Drury
32 S.W.3d 521 (Court of Appeals of Kentucky, 2000)
Jones v. Hammond
329 S.W.3d 331 (Court of Appeals of Kentucky, 2010)
Humphrey v. Humphrey
326 S.W.3d 460 (Court of Appeals of Kentucky, 2010)
Keplinger v. Keplinger
839 S.W.2d 566 (Court of Appeals of Kentucky, 1992)
Floyd County Board of Education v. Ratliff
955 S.W.2d 921 (Kentucky Supreme Court, 1997)
Anderson v. Johnson
350 S.W.3d 453 (Kentucky Supreme Court, 2011)
Brooks v. Brooks
350 S.W.3d 823 (Court of Appeals of Kentucky, 2011)
Kulas v. Kulas
898 S.W.2d 529 (Court of Appeals of Kentucky, 1995)
Penner v. Penner
411 S.W.3d 775 (Court of Appeals of Kentucky, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Ashley Layman v. Richard Lee Bohanon Jr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashley-layman-v-richard-lee-bohanon-jr-ky-2020.