Craig Wilson Cole v. Joy Teressa Bonnette Cole

CourtLouisiana Court of Appeal
DecidedJune 4, 2014
DocketCA-0013-1442
StatusUnknown

This text of Craig Wilson Cole v. Joy Teressa Bonnette Cole (Craig Wilson Cole v. Joy Teressa Bonnette Cole) 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
Craig Wilson Cole v. Joy Teressa Bonnette Cole, (La. Ct. App. 2014).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

13-1442

CRAIG WILSON COLE

VERSUS

JOY TERESSA BONNETTE COLE

**********

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 2008-2414-B/A HONORABLE MARK A. JEANSONNE, DISTRICT JUDGE

JOHN E. CONERY JUDGE

Court composed of John D. Saunders, James T. Genovese, and John E. Conery, Judges.

AFFIRMED.

Rodney M. Rabalais Attorney at Law Post Office Box 447 Marksville, Louisiana 71351 (318) 253-4622 COUNSEL FOR PLAINTIFF/APPELLANT: Craig Wilson Cole Cory P. Roy Brandon J. Scott Benjamin D. James Roy & Scott Attorneys at Law 107 North Washington Street Marksville, Louisiana 71351 (318) 240-7800 COUNSEL FOR DEFENDANT/APPELLEE: Joy Teressa Bonnette Cole CONERY, Judge.

In this child support case, the father, Craig Wilson Cole, appeals the trial

court’s judgment increasing the child support award for their minor child from

$288.00 to $872.12 per month, finding a material change of circumstances from

the last time the child support award was set. The trial court based its ruling on

evidence presented that Craig’s custody of the minor child was no longer a shared

custody arrangement, but a de facto joint custody arrangement. Support was set

pursuant to statute using the joint custody guidelines required by the application of

Worksheet A and not Worksheet B, shared custody, for a proper determination of

the child support award. The trial court also found that Craig’s income increased

due to regular and consistent overtime earnings. Finding no abuse of discretion, we

affirm.

FACTS AND PROCEDURAL HISTORY

Joy Teressa Bonnette Cole and Craig Wilson Cole were married on

December 5, 1998, and are the parents of one minor child, a son born August 30,

2005. There is a history of disputes between the parties concerning the terms of

both the custody arrangement and the amount of child support.

On August 4, 2008, the parties filed a joint petition for divorce seeking joint

custody and a designation as co-domiciliary status. A consent judgment was

signed by the trial court appointing Joy as the domiciliary parent and awarding

Craig visitation privileges. Craig agreed to and was ordered to pay Joy $500.00 a

month in child support for their minor child.

Since the original consent judgment in 2008, the parties have entered into

four other consent judgments relating to both custody and child support. On

October 18, 2012, the parties agreed to the last of the four consent judgments. The October 18, 2012 Consent Judgment allowed Craig additional time with the minor

child, including extended alternating four-day weekends, two weekdays per week,

and additional time during the summer. The addition of these days changed the

custody of the minor child from joint to shared custody, requiring coordination

with the “father’s work schedule so that each parent enjoys an equal amount of

time with the child.” Craig’s monthly child support award was reduced from

$774.04 to $288.00 using the child support guidelines for shared custody contained

in Worksheet B.

Following the entry of the October 18, 2012 Consent Judgment, Joy filed a

motion asking that an evidentiary hearing be re-fixed to address a change in

circumstances. Joy claimed that the October 18, 2012 Consent Judgment was no

longer in the best interests of the minor child and sought a hearing to address

“custody, visitation and support.” The trial court held a hearing on February 15,

2013, and issued oral reasons from the bench. On March 19, 2013, a considered

decree was signed. However, the record of the February 15, 2013 hearing only

addressed the issue of custody. There is no evidence in that record of any

testimony relating to the issue of child support.

In the March 19, 2013 Considered Decree, the trial court determined that

custody between the parents remain shared. However, the trial court modified the

October 18, 2012 Consent Judgment by increasing Craig’s every other weekend

schedule to five days, beginning on Thursday at 10:00 a.m. and concluding on

Tuesday at 5:00 p.m. The weekday schedule was reduced to “One two-day, one

night block each and every month commencing at 10:00 a.m. and ending at 5 p.m.

the next day.” The trial court also ordered Craig to choose the two days and one

2 night upon receiving his work schedule each month and to notify Joy immediately

of the time he wished to exercise custody.

The March 19, 2013 Considered Decree provided that “all other provisions

contained in any previous judgment that are not in conflict with this Judgment shall

remain in force and effect.” Per the provisions of the March 19, 2013 Considered

Decree, the $288.00 award for monthly child support remained “in force and

effect” as ordered in the October 18, 2012 Consent Judgment.

Two months later, on May 21, 2013, Joy filed a rule to increase child

support on the basis that the modification of visitation in the March 19, 2013

Considered Decree changed the child custody arrangement from shared back to

joint custody, and justified an increase in the child support award. Additionally,

Joy also sought an increase in child support due to an increase in Craig’s income

from regular overtime pay.

On August 19, 2013, the trial court held a hearing to address the issues

raised in Joy’s May 21, 2013 rule. The trial court issued a ruling on September 4,

2013, and assigned written reasons for judgment. The trial court found that the

actual time that the minor child was in Craig’s physical custody did not conform

with the custodial times set forth in either the March 19, 2013 Considered Decree

or the October 18, 2012 Consent Judgment and, therefore, no longer met the

statutory and/or jurisprudential definition of shared custody. The $288.00 per

month child support award had been calculated premised on a shared custody plan

where each party would have the child equally. In its September 4, 2013 ruling,

the trial court found factually that a de facto joint custody scheme was in effect

between the parties and not a shared custody plan. The actual time the minor child

was in the parents’ custody was found to be 61% with Joy and 39% with Craig

3 and, therefore, was commensurate with the statutory definition of joint custody.

This finding resulted in a material change in circumstances. The trial court

exercised its considerable discretion and applied Worksheet A, rather than

Worksheet B, for a determination of Craig’s child support obligation under the de

facto joint custody plan then existing between the parties.

The trial court then considered the issue of Craig’s overtime pay as an

additional basis for a material change in circumstances. Craig testified that his

income had increased since the October 18, 2012 Consent Judgment based on his

overtime work schedule. Craig testified that he consistently worked overtime and

was expected to continue to do so for the foreseeable future.

The trial court found that based on Craig’s new income figures, the

“payment of $288.00 is not fair or adequate for the child.” The trial court ruled

Craig’s increase in income, based on his pay for consistent overtime work,

provided another basis for a material change in circumstances.

The trial court ordered that Craig’s child support obligation be modified

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