Braswell v. Braswell

CourtCourt of Appeals of North Carolina
DecidedDecember 3, 2024
Docket24-74
StatusPublished

This text of Braswell v. Braswell (Braswell v. Braswell) 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
Braswell v. Braswell, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-74

Filed 3 December 2024

Wake County, No. 23 CVD 8457

LORETTA BRASWELL, Plaintiff,

v.

RICHARD D. BRASWELL, Defendant.

Appeal by defendant from order entered 28 August 2023 by Judge Anna E.

Worley in Wake County District Court. Heard in the Court of Appeals 13 August

2024.

Sandlin Family Law Group, by Deborah Sandlin, and Raleigh Divorce Law Firm, by Heather Williams Forshey, Jennifer Sinclair Simpkins, and Katelyn Bailey Hodgins, for plaintiff-appellee.

The Armstrong Law Firm, P.A., by L. Lamar Armstrong, III, for defendant- appellant.

THOMPSON, Judge.

Richard D. Braswell (“defendant”) appeals an interlocutory order denying his

Motion to Transfer Venue (the “Venue Motion”). On appeal, defendant argues that

the trial court erred in concluding that he had waived his right to challenge venue.

After careful review, we affirm.

I. Factual Background and Procedural History BRASWELL V. BRASWELL

Opinion of the Court

Loretta Braswell (“plaintiff”) and defendant were married in 2013 and

separated in 2022. Plaintiff and defendant had one child from their marriage, born

on 13 December 2007. During their marriage, plaintiff and defendant lived in

Johnston County with the minor child. On 13 April 2023, plaintiff filed a complaint

in Wake County District Court seeking child support, post-separation support,

alimony, equitable distribution, and to set aside a premarital agreement. At the time

of plaintiff’s complaint, plaintiff and the minor child resided in Wayne County, while

defendant resided in Johnston County.

On 15 May 2023, defendant timely filed his Venue Motion, requesting that this

action be moved to Johnston County. As a basis for transfer, defendant asserted that

the parties lived in Johnston County for the duration of their marriage and at the

time of their separation, and neither party nor the minor child lived in Wake County

at any time in the year preceding the filing of plaintiff’s complaint. Plaintiff filed an

objection and response to defendant’s Venue Motion on 16 May 2023. In plaintiff’s

objection, she argued that Wake County was an appropriate venue for the following

reasons: (1) plaintiff was displaced from her residence due to defendant’s actions and

had no permanent residence following the separation; (2) defendant held a political

position in Johnston County, had influential status within the community, and was

associated with members of the community that held positions of power, to such a

degree that his position would be a barrier to a fair adjudication; (3) Wake County is

in close proximity to Johnston County, defendant’s county of residence, and is not an

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inconvenient forum for him; and (4) defendant actively engaged with plaintiff in a

different lawsuit in Wake County. Shortly thereafter, defendant filed a calendar

request and notice of hearing, calendaring his Venue Motion to be heard on 12 July

2023.

On 13 June 2023, nearly one month after filing his Venue Motion—but a month

before the 12 July 2023 hearing on the Venue Motion—defendant filed a motion to

dismiss, motion to strike, affirmative defenses, answer, and critically for purposes of

this appeal, counterclaims for equitable distribution and a claim for child custody.

Notably, prior to the filing of defendant’s counterclaims for temporary and permanent

child custody, child custody was not a pending issue before the trial court. Stated

differently, defendant asserted a new claim in the present action.

On 12 July 2023, defendant’s Venue Motion was heard in Wake County District

Court. The trial court considered the parties’ arguments, North Carolina case law

and persuasive federal case law, and the factors set forth in N.C. Gen. Stat. § 1-83.

The trial court found that defendant’s custody claim was not one that had to be raised

in the present action, as it could have been raised at any time. Defendant could have

pursued other legal options regarding the custody claim that would have avoided the

issue of waiver. However, because defendant filed the counterclaim regarding

custody, which was not previously pending before the trial court, defendant “actively

participated” in the litigation. Consequently, because defendant actively participated

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in the action, he availed himself to the jurisdiction of Wake County and waived his

objection to the respective venue.

By written order dated 8 August 2023, the trial court denied defendant’s Venue

Motion, concluding that defendant had waived his right to challenge venue by filing

the counterclaim for child custody in Wake County District Court on 13 June 2023.

From this order, defendant filed timely written notice of appeal.

II. Discussion

On appeal, defendant contends that the trial court erred in concluding that

defendant had waived his venue defense. We do not agree.

A. Appellate Jurisdiction

As an initial matter, “[a]lthough the initial question of venue is a procedural

one, there can be no doubt that a right to venue established by statute is a substantial

right[,]” and “its grant or denial is immediately appealable.” Gardner v. Gardner, 300

N.C. 715, 719, 268 S.E.2d 468, 471 (1980). N.C. Gen. Stat. § 1-82, which governs

venue, provides that an “action must be tried in the county in which the plaintiffs or

the defendants, or any of them, reside at its commencement . . . .” N.C. Gen. Stat. §

1-82 (2023). Because defendant’s right to venue is established by N.C. Gen. Stat. § 1-

82, the trial court’s denial of defendant’s Venue Motion affects a substantial right and

is “immediately appealable.” Gardner, 300 N.C. at 719, 268 S.E.2d at 471.

Consequently, we dismiss defendant’s petition for writ of certiorari as moot.

B. Standard of review

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“North Carolina precedent has engaged in a fact-based de novo inquiry into

whether a party waives an improper venue defense as a question of law.”

LendingTree, LLC v. Anderson, 228 N.C. App. 403, 407, 747 S.E.2d 292, 296 (2013).

“Under a de novo review, th[is] [C]ourt considers the matter anew and freely

substitutes its own judgment for that of the lower tribunal.” Id. at 407–08, 747 S.E.2d

at 296 (citation omitted).

C. Venue Motion

The dispositive issue before the Court in the present case is whether defendant

waived his 15 May 2023 venue objection by filing a non-compulsory counterclaim in

the same venue defendant asserted was improper, prior to the trial court ruling on

his Venue Motion. We conclude that defendant did waive his venue defense.

As noted above, N.C. Gen. Stat. § 1-82 requires that “the action must be tried

in the county in which the plaintiffs or the defendants, or any of them, reside at its

commencement . . . .” N.C. Gen. Stat. § 1-82. However, N.C. Gen. Stat. § 1-83 provides

that if the county designated in the summons and complaint “is not the proper one,

the action may, however, be tried therein [the incorrect venue], unless the defendant,

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Hillis v. Heineman
626 F.3d 1014 (Ninth Circuit, 2010)
Gardner v. Gardner
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71 S.E.2d 54 (Supreme Court of North Carolina, 1952)
Miller v. Miller
247 S.E.2d 278 (Court of Appeals of North Carolina, 1978)
Swift and Company v. Dan-Cleve Corp.
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Shaver v. . Huntley
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Stokes v. Stokes
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Lendingtree, LLC v. Anderson
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Bluebook (online)
Braswell v. Braswell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/braswell-v-braswell-ncctapp-2024.