Barham v. Barham

CourtCourt of Appeals of North Carolina
DecidedDecember 6, 2022
Docket22-340
StatusPublished

This text of Barham v. Barham (Barham v. Barham) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barham v. Barham, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-798 No. COA22-340

Filed 6 December 2022

Buncombe County, No. 10 CVD 4766

DR. TRAVIS PG BARHAM, Plaintiff,

v.

LYNNE M. BARHAM, Defendant.

Appeal by plaintiff from orders entered 2 August 2021 by Judge Ward D. Scott

in Buncombe County District Court. Heard in the Court of Appeals

2 November 2022.

Connell & Gelb PLLC, by Michelle D. Connell; Mary E. Arrowood; and Fox Rothschild LLP, by Troy D. Shelton, for plaintiff-appellant.

Emily Sutton Dezio, PA, by Emily Sutton Dezio, for defendant-appellee.

ARROWOOD, Judge.

¶1 Dr. Travis PG Barham (“plaintiff”) appeals from the trial court’s orders of civil

contempt for the failure to comply with his child support obligations, the grant of

attorney’s fees to Lynne M. Barham (“defendant”), and the imposition of Rule 11

sanctions. For the following reasons, we affirm the trial court’s orders of contempt

and attorney’s fees and reverse the imposition of Rule 11 sanctions.

I. Background

¶2 Plaintiff and defendant were married on 21 February 1976. They are the BARHAM V. BARHAM

2022-NCCOA-798

Opinion of the Court

parents of eight children, with their last child, Timothy, turning 18 on

30 August 2020 and graduating from high school in June 2021. Litigation between

the parties began when plaintiff filed a complaint for child custody, child support, and

equitable distribution on 10 September 2010. The parties were divorced by judgment

of absolute divorce entered 6 June 2011.

¶3 Since 2011 there have been numerous court orders regarding child support,

child custody, and alimony. On 27 February 2018, the parties signed a gatekeeper

order stating “neither party shall file a motion for modification of custody or support

without prior approval by the presiding judge.”

¶4 After the parties’ seventh child graduated from high school, plaintiff filed a

motion to modify child support on 23 August 2019. This motion resulted in a consent

order filed 10 January 2020 requiring plaintiff to pay $716.00 per month to commence

on 1 February 2020 “pending further orders.” This order also specified that it was a

“final order resolv[ing] all matters [now] pending.” Instead of the ordered amount,

plaintiff began paying one cent per pay period on 17 January 2020.

¶5 On 26 February 2020, plaintiff filed a motion “to establish credit for over-

payment of child support.” Plaintiff’s motion stated that he “ha[d] a credit for

overpayment of child support . . . in the amount of $12,486.95” and “desire[d] his

overpayment of child support be applied to his ongoing child support obligation

effective February[] 2020 as he ha[d] already paid this child support in advance.” BARHAM V. BARHAM

Plaintiff’s motion rested on the contention that each year from 2013 to 2019 he

mistakenly made 26 payments instead of the required 24, establishing a “credit” of

$12,486.95.

¶6 Defendant filed a motion for contempt on 11 May 2020 due to plaintiff’s failure

to abide by the 10 January 2020 child support order. The trial court entered an order

to appear and show cause on 22 May 2020. On 4 June 2020, defendant filed a motion

for Rule 11 sanctions alleging that plaintiff was not acting in good faith and lacked a

viable legal claim for his motion to establish credit. Plaintiff took a voluntary

dismissal of his motion on 27 October 2020 in order to use this argument as a defense

to defendant’s motion for contempt. The foregoing matters were heard by the trial

court, Judge Scott presiding, on the 4th, 5th, 24th, and 25th of February 2021.

¶7 After trial, the court found plaintiff was in willful contempt for nonpayment of

child support. Judge Scott listed 29 factual findings to support his conclusion and

found plaintiff owed defendant $9,307.72 due to missed payments ranging from

February 2020-February 2021. The trial court made findings illustrating that it

considered the statutory factors set forth in N.C. Gen. Stat. § 50-13.4(c), including

“the reasonable needs of the child for health, education, and maintenance, having due

regard to the estates, earnings and accustomed standard of living of the child and the

parties, the childcare . . . contributions of each party and other facts of the particular

case.” Additionally, the trial court found: BARHAM V. BARHAM

14. At trial, [plaintiff] argued that he had “pre-paid” his child support obligation from February 2020 forward by paying 26 payments from 2013-2019. It is well- established law in North Carolina, that prospective child support vests the day it is due. Additionally, [plaintiff’s] claim is contradicted by his testimony that his payment of 26 payments per year were the result of his unilateral mistake.

....

16. [Plaintiff’s] position ignores the . . . opportunities for him to correct his unilateral mistake noting the several child support orders entered on this subject since 2013. [Plaintiff] is asking the [c]ourt to apply payments he made in 2013, 2014, 2015, 2016, 2017, 2018 and 2019 to a future obligation in 2020.

19. The [c]ourt finds to accept [plaintiff’s] proposition would place [defendant] in an undue hardship and that Timothy is unable to presently benefit from overpayments [plaintiff] made in 2013, 2014, 2015, 2016, 2017, 2018 and 2019.

23. [Plaintiff’s] actions to reduce his payment to $0.01 per pay period during the pendency of this action shows a willful act to purposefully violate the January 10, 2020 [o]rder. [Plaintiff] made a willful, calculated and deliberate decision to alter his payroll records to pay a lesser amount than obligated by the January 10, 2020 [o]rder. This willfulness is compounded by the fact that he reduced his child support payments without first filing a motion with this [c]ourt, even though the January 10, 2020 [o]rder specifies that he would continue paying $716 per BARHAM V. BARHAM

month “pending further orders.” The law has long prohibited parties from engaging in self-help remedies.

25. The [c]ourt finds that [plaintiff] has had at all times the ability to pay the child support as ordered and currently has the present ability to pay and means to comply with the January 10, 2020 [o]rder.

¶8 The trial court also ordered plaintiff to pay reasonable attorney’s fees provided

by N.C. Gen. Stat. § 50-13.6. Based on the affidavit of attorney’s fees filed with the

trial court on 16 March 2021, plaintiff was ordered to pay $5,406.25.

¶9 Defendant’s motion for Rule 11 sanctions filed in response to plaintiff’s

26 February 2020 motion to establish credit for overpayment of child support was

also granted. In pertinent part the trial court made the following findings of fact:

9. Beginning January 17, 2020, [plaintiff] began paying [defendant] one cent per pay period in child support, without first seeking any additional modification of child support from this [c]ourt. He has continued paying child support at this rate past February 1, 2020, and to the present.

11. Defendant argued, and the [c]ourt agreed, that there was no allowable claim under existing North Carolina law to provide the relief [p]laintiff requested. [Plaintiff’s m]otion for “[c]redit” for Over-Payment of Child Support filed on February 26, 2020 lacked a legal basis under existing North Carolina law for the relief requested. The [c]ourt held a conference with BARHAM V. BARHAM

counsel to review his independent research into whether North Carolina law recognized [plaintiff’s] claim.

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Barham v. Barham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barham-v-barham-ncctapp-2022.