Consuela M. Brown v. Steven L. Roquet

CourtCourt of Appeals of Iowa
DecidedFebruary 19, 2020
Docket19-0528
StatusPublished

This text of Consuela M. Brown v. Steven L. Roquet (Consuela M. Brown v. Steven L. Roquet) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consuela M. Brown v. Steven L. Roquet, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 19-0528 Filed February 19, 2020

CONSUELA M. BROWN, Plaintiff-Appellant,

vs.

STEVEN L. ROQUET, Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Wapello County, Lucy J. Gamon,

Judge.

Consuela Brown appeals the district court child support order. AFFIRMED

AS MODIFIED AND REMANDED.

Danni J. Harris and Kimberly S. Bartosh (until withdrawal) of Whitfield &

Eddy, P.L.C., Des Moines, for appellant.

Heather M. Simplot and Patrick F. Curran of Harrison, Moreland, Webber,

Simplot & Maxwell, P.C., Ottumwa, for appellee.

Heard by Tabor, P.J., and Greer and Ahlers, JJ. 2

GREER, Judge.

Consuela Brown appeals an order imposing a past child support obligation

on Steven Roquet for their minor child. Consuela argues the court should not have

used half of the child’s personal injury settlement to reduce Steven’s past support

obligation and should have assessed a higher interest rate on the past payments.

She asks for appellate attorney fees. We conclude the district court should not

have used the settlement to reduce the past child support award and the court

should have imposed a ten percent interest rate, but this interest rate applies only

if Steven is more than thirty days delinquent on a payment. We grant Consuela

appellate attorney fees. We remand for entry of an order consistent with this

opinion.

I. Background Facts and Proceedings.

From July 2008 until January 2018, Consuela and Steven had an on-again,

off-again relationship, which produced one child, T.B., born in 2009. Consuela did

not inform Steven she was pregnant until six months into the pregnancy. Yet no

paternity testing occurred until July 2013. As their son matured, they learned he

had intellectual disabilities and several medical concerns. The child has received

government benefits throughout his life. No formal child support order existed

before this case, but Steven intermittently gave Consuela money and paid for

items.1

1Steven has been married to another woman since 1985. Steven did not want his wife or their children to find out about his affair or T.B., a driving force behind the parties avoiding a formal support order. 3

In July 2013, a dog bit T.B. in the face causing serious injuries. Consuela

filed a personal injury claim on the child’s behalf.2 The claim ultimately settled with

the child allocated net proceeds of $43,697.22. A conservatorship was established

for T.B. with the mother appointed as conservator to manage the funds for his

benefit. Consuela, with help from counsel and agreement of the Iowa Department

of Human Services and the district court, preserved the settlement funds by

investing them in her home to pay off the mortgage. This arrangement prevented

the payment of settlement funds from affecting T.B.’s ability to keep receiving

government benefits for his developmental and medical needs. As a part of her

fiduciary duty as the conservator, Consuela intends to pay T.B. the settlement

funds plus interest when he is an adult.

For reasons unimportant here,3 on December 12, 2016, Consuela finally

petitioned to establish paternity, custody, visitation, and child support. At the time,

because there was an ongoing juvenile court case involving the child, this case

was stayed pending resolution of the juvenile court proceedings. The stay lifted in

January 2018.

2 The record does not reflect what Steven knew about the dog bite case or the settlement when it occurred. 3 On this record, the reasons for waiting to file for child support are not clear nor

are they relevant to the purpose of child support and Steven’s obligation to provide for his child. For example, Consuela testified Steven promised marriage but needed time to resolve complicated financial issues and even sent her cards calling her “his wife.” And Consuela believed from Steven’s statements that if she filed this action he would take custody of their child. Whether true or not, Steven alluded to Consuela that he had power and influence. 4

After legal posturing, the parties stipulated to joint legal custody, future child

support,4 Consuela having physical care of the child, and Steven having visitation.

As for the remaining issues, after a two-day bench trial, the district court entered a

decree concluding that Steven should have been paying $1703.23 per month

during T.B.’s life over a period of 106 months. The court found his past total child

support obligation without deductions totaled $180,542.38. Then the court applied

six deductions to this total amount: (1) $14,000 for giving Consuela use of a Dodge

van; (2) $9902.84 for paying for gasoline; (3) $1478.34 for paying for auto parts;

(4) $21,844.61 for half of the personal injury settlement proceeds T.B. received

from his dog bite case; (5) $19,759.14 for social security disability income the child

received; and (6) $50,000 for cash gifts he provided to Consuela. After these

deductions, the court entered judgment against Steven for $63,557.45, paid at the

rate of $500 per month. The order required Steven to pay interest on the judgment

at the statutory rate from the date of the entry of the decree. Both parties moved

to reconsider, enlarge, or amend.

On March 6, the district court enlarged and amended the decree. It ordered

a 4.54% post-judgment interest rate on the past child support payments. The court

denied Consuela’s request to increase the amount of Steven’s past child support

obligation and increase the monthly installments he must pay. Consuela appeals.

4 With regard to future child support, the parties stipulated to a monthly obligation of $1483.98, using $15,080 for Consuela’s income and $205,702 for Steven’s income. 5

II. Standard of Review.

“Generally, in paternity actions, we review issues ‘ancillary to the question

of paternity, such as support,’ de novo. Markey v. Carney, 705 N.W.2d 13, 19

(Iowa 2005) (quoting Dye v. Geiger, 554 N.W.2d 538, 539 (Iowa 1996)); see also

Iowa R. App. P. 6.907 (“Review in equity cases shall be de novo.”).

III. Analysis.

Consuela narrowed her appeal to a few issues. First, she objects to the

dog bite settlement deduction. We first address the deduction to the total amount

of Steven’s past support obligation. Then, we will discuss the appropriate interest

rate to apply to the payments. Finally, we address Consuela’s request for

appellate attorney fees.

A. Personal Injury Settlement Reduction. “Unlike a current child support

obligation, the guidelines are not used to establish the amount of past child

support.” Markey, 705 N.W.2d at 24; see also Iowa Code § 600B.25 (2016).

Instead, the “court may order the father to pay amounts the court deems

appropriate for the past support and maintenance of the child.” Iowa Code

§ 600B.25(1). “This standard permits the court to consider all the surrounding facts

and circumstances to determine the amount in light of the purpose of child support

and the duty of a parent to pay child support.” Markey, 705 N.W.2d at 24

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Related

In Re the Marriage of Foley
501 N.W.2d 497 (Supreme Court of Iowa, 1993)
State Ex Rel. Tack v. Sandholdt
519 N.W.2d 414 (Court of Appeals of Iowa, 1994)
In Re Marriage of McNerney
417 N.W.2d 205 (Supreme Court of Iowa, 1987)
In Re Marriage of Liebich
547 N.W.2d 844 (Court of Appeals of Iowa, 1996)
Dye v. Geiger
554 N.W.2d 538 (Supreme Court of Iowa, 1996)
In Re the Marriage of Ales
592 N.W.2d 698 (Court of Appeals of Iowa, 1999)
Markey v. Carney
705 N.W.2d 13 (Supreme Court of Iowa, 2005)
In Re the Marriage of Hoak
364 N.W.2d 185 (Supreme Court of Iowa, 1985)

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Consuela M. Brown v. Steven L. Roquet, Counsel Stack Legal Research, https://law.counselstack.com/opinion/consuela-m-brown-v-steven-l-roquet-iowactapp-2020.