Hillary Noel-Potier v. Richard Potier

CourtLouisiana Court of Appeal
DecidedOctober 30, 2024
DocketCA-0024-0194
StatusUnknown

This text of Hillary Noel-Potier v. Richard Potier (Hillary Noel-Potier v. Richard Potier) 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
Hillary Noel-Potier v. Richard Potier, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 24-194

HILLARY NOEL-POTIER

VERSUS

RICHARD POTIER

**********

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN, NO. 91132 HONORABLE CURTIS SIGUR, DISTRICT JUDGE

ELIZABETH A. PICKETT CHIEF JUDGE

Court composed of Elizabeth A. Pickett, Sharon Darville Wilson, and Guy E. Bradberry, Judges.

AFFIRMED.

John W. Milton King Milton Law Group, L.L.C. 213 East Willow Street Lafayette, LA 70501 (337) 548-3030 COUNSEL FOR PLAINTIFF-APPELLANT: Hillary Noel-Potier

Lucretia P. Pecantte Lucretia Pecantte & Associates 124 W. Washington Street, Suite B New Iberia, LA 70562 (337) 374-1202 COUNSEL FOR DEFENDANT-APPELLEE: Richard Potier PICKETT, Chief Judge.

The plaintiff appeals the trial court’s judgment granting the defendant’s

motion to deem his sworn detailed descriptive list as a judicial determination of the

community of assets and liabilities existing between them during their marriage.

We affirm.

FACTS

On December 20, 2021, Richard Potier filed a petition seeking a divorce

from Hillary Noel-Potier. With regard to incidental matters, Mr. Potier requested

“both parties be ordered to file a sworn detailed descriptive list[] with forty-five

days of the service[] of this petition setting forth al [sic] community assets and

liabilities and all reimbursement claims.” The trial court signed an order on

December 28, 2021, which provides, in pertinent part:

IT IS ORDERED, ADJUDGED AND DECREED that HILLARY NOEL-POTIER show cause on the 9th day of February, 2022 at 10:30 A.m. . . . why the court should not set a date for the filing of the sworn detailed descriptive lists of the community of property.

Mr. Potier filed his detailed descriptive list (hereinafter “DDL”) on July 5,

2022. Thereafter, on November 28, 2022, he filed a rule to show cause why his

DDL should not be deemed a judicial determination of the community of assets

and liabilities existing between him and Ms. Noel-Potier. According to the record,

Ms. Noel-Potier had not filed her own DDL before the May 24, 2023 hearing on

Mr. Potier’s rule to show cause. During that hearing, counsel for Ms. Noel-Potier

argued (1) he had not been served with an order setting the deadline for filing the

DDL and (2) Ms. Noel-Potier’s DDL had been filed before Mr. Potier filed his rule

to show cause why his DDL should not be deemed to constitute the community

between the parties. Ms. Noel-Potier also argued Mr. Potier’s DDL should not be

“deemed to constitute a judicial determination of the community assets and liabilities[,]” as provided by La.R.S. 9:2801(A)(1)(a), because: a) there was a

miscommunication between the parties regarding the separation of community

property; b) Ms. Noel-Potier relied on recommendations made by the Hearing

Officer; c) Mr. Potier’s DDL is totally incomplete; d) some assets not listed on Mr.

Potier’s DDL are listed in another judgment as being community property; and e)

the parties stipulated that certain items not included on Mr. Potier’s DDL were

community property; therefore, those items should be deemed community

property.

At the conclusion of the hearing, the trial court allowed the parties time to

file additional briefs supporting their positions. Thereafter, the court issued

Reasons for Judgment finding Ms. Noel-Potier did not establish she had good

cause for failing to timely file her DDL and issued a judgment on August 4, 2023,

granting Mr. Potier’s rule to show cause and deeming his DDL as the community

of assets and liabilities existing between the parties. Ms. Noel Potier filed this

appeal.

DISCUSSION

Ms. Noel-Potier assigns one error on appeal: the trial court erred in holding

the parties had been ordered to file their DDLs within forty-five days. In paragraph

10 of his Petition for Divorce, Mr. Potier requested both parties be ordered to file

their DDLs within forty-five days of service of notice. In support of her position,

Ms. Noel-Potier points to the specific language of the December 28, 2020 order

signed by the trial court that addresses the deadline for the parties to file their

DDLs, which states: “why the court should not set a date for the filing of the sworn

detailed descriptive lists of the community of property.” She is correct that she was

not ordered to file her DDL within forty-five days of a specific date, but she fails to

acknowledge La.R.S. 9:2801 which establishes a deadline for parties to file their 2 DDLs. Mr. Potier filed his DDL on July 5, 2022, and his rule to have his DDL

deemed to constitute the assets and liabilities of the community on November 28,

2022.

In ruling on Mr. Potier’s rule to show cause, the trial court referenced the

procedure for spouses to partition community property and settle other claims

arising from the termination of their matrimonial regime set forth in La.R.S.

9:2801. Louisiana Revised Statutes 9:2801(A)(1)(a) which governs the procedure

for the filing of the parties’ DDLs and provides, in pertinent part: “Within forty-

five days of service of a motion by either party, each party shall file a sworn

detailed descriptive list of all community property[.]” If one party fails to file her

DDL timely, the other party can file a rule to show cause why his DDL “should not

be deemed to constitute a judicial determination of the community assets and

liabilities.” Id. At the hearing on that rule, the trial court “may either grant the

request or, for good cause shown, extend the time period for filing a sworn detailed

descriptive list.” Id. If the trial court grants the request, the DDL is deemed to

constitute the community of assets and liabilities and cannot be traversed. Id.

The trial court pointed out in its Reasons for Judgment that Ms. Noel-Potier

had been served with Mr. Potier’s petition for divorce why the parties should not

be ordered to file their DDLswithin forty-five days of service on January 6, 2022.

Ms. Noel-Potier did not deny being served with Mr. Potier’s petition for divorce.

Rather, she denied being ordered to file her DDL within forty-five days of a certain

date which is correct. Nonetheless, the trial court noted La.R.S. 9:2801(A)(1)(a)

establishes a forty-five-day statutory deadline for parties to file their DDLs.

Neither party met that deadline.

The transcript of the May 24, 2023 hearing on Mr. Potier’s motion to have

his DDL deemed to constitute the community between the parties shows Ms. Noel- 3 Potier’s DDL was not in the record due to insufficient filing fees. Ms. Noel-Potier

submitted her DDL on November 30, 2022, two days after Mr. Potier filed his rule

to show cause. She argued she filed her DDL earlier, but the signature page of the

DDL is dated November 29, 2022. The outstanding fees were not paid until June

27, 2023, seven months after she submitted her DDL to the clerk of court’s office

and almost one year after Mr. Potier filed his DDL.

In Gauthier v. Gauthier, 04-198, pp. 3–4 (La.App. 3 Cir. 11/10/04), 886

So.2d 681, 684–85, this court addressed the issue of good cause in relation to the

filing of DDLs, stating:

Although there is no jurisprudential guidance on the meaning of good cause in relation to La.R.S. 9:2801, several courts have discussed the role of good cause in deciding whether or not to extend time in other contexts.

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