Hoffman Partnership, LLP v. Circuit Court of Spotsylvania County

CourtCourt of Appeals of Virginia
DecidedJune 16, 2020
Docket0581202
StatusPublished

This text of Hoffman Partnership, LLP v. Circuit Court of Spotsylvania County (Hoffman Partnership, LLP v. Circuit Court of Spotsylvania County) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoffman Partnership, LLP v. Circuit Court of Spotsylvania County, (Va. Ct. App. 2020).

Opinion

VIRGINIA: In the Court of Appeals of Virginia on Tuesday the 16th day of June, 2020. PUBLISHED

Hoffman Partnership, LLP, t/a Lafayette Complex, by Garry Lee Hoffman, partner and Garry Lee Hoffman, Petitioners,

against Record No. 0581-20-2

Circuit Court of Spotsylvania County, Respondent.

Upon a Petition for a Writ of Prohibition

Before Judges O’Brien, Malveaux, and Senior Judge Frank

On April 15, 2020, Hoffman Partnership, LLP, by Garry Lee Hoffman and Garry Lee Hoffman,

individually (collectively “petitioners”), filed a petition for writ of prohibition directed to the presiding judge

of the Circuit Court of Spotsylvania County (“respondent”) in a pending divorce case. Petitioners pray that

this Court issue a writ of prohibition to the circuit court to prohibit the presiding judge from exercising

jurisdiction over them in the divorce proceedings, and prohibit enforcement of a pendente lite order entered in

December 2017 and a contempt order entered in April 2019 in those proceedings.

The respondent moved to dismiss the petition, arguing that this Court does not have jurisdiction to

consider it and that prohibition does not lie under the circumstances. Beth Lee Hoffman (“wife”), a party in

interest opposed to the relief sought, filed a separate response through her private counsel.1 Upon

consideration of the verified petition and brief in support, and the motions to dismiss and briefs in support, we

deny the petition.

1 Wife also asserts that husband does not have authority to act on behalf of the partnership, over which the circuit court granted her management authority; thus we should dismiss the partnership from the petition. Given our disposition of the petition, we find it unnecessary to address this argument. The doctrine of judicial restraint requires us to decide the case on the “best and narrowest” grounds. See, e.g., Chaney v. Karabaic-Chaney, 71 Va. App. 431, 438 (2020); Commonwealth v. Swann, 290 Va. 194, 196 (2015). Background

On September 18, 2017, wife filed for divorce from Garry Lee Hoffman (“husband”) in the Circuit

Court of Spotsylvania County. See Renee Beth Hoffman v. Garry Lee Hoffman, Record No. CL17-1502.

Petitioner Hoffman Partnership, LLP (“the partnership”) is a limited liability partnership, in which husband

and wife are sole partners.2 The partnership owns several parcels of real property in Fredericksburg and

generates income through rent collected from those properties.

Wife’s complaint for divorce sought, inter alia, a no-fault divorce, spousal support or a reservation of

support, and equitable distribution of the marital estate. As relevant here, wife expressly prayed in the

complaint for divorce that she “be permitted to continue to manage” the partnership, both pendente lite and

permanently. Wife affirmatively alleged that the partnership was “a marital enterprise” and she had managed

the partnership during the marriage. Husband filed a counterclaim for divorce in which he also sought, inter

alia, equitable distribution of the marital estate; the counterclaim did not separately address the partnership or

controvert wife’s assertion that it was marital property.3

On December 18, 2017, following a hearing on the record, the circuit court entered a pendente lite

order. Among other things, the pendente lite order awarded wife control and management of the partnership;

thus, wife was to “be responsible for making daily decisions” regarding the partnership and to “apprise”

husband, through counsel, “of all managerial decisions regarding” the partnership. To facilitate its order, the

circuit court directed husband to provide wife “with all information, files, and documentation necessary to

manage” the partnership, “including, but not limited to, keys, checkbooks, receipt books, a copy of [the

partnership’s] QuickBooks programs, copies of bank statements for this business, access to all bank accounts

2 The original partnership was formed on May 29, 1987; it issued a restatement of partnership on May 31, 2001; and it registered with the State Corporation Commission as a limited liability partnership on February 25, 2002. 3 The voluminous materials presented to this Court do not include any answer to wife’s complaint that husband may have filed. -2- holding any funds of [the partnership] and a list of any known repairs or tenant concerns that need to be

addressed.” Husband did not comply with the circuit court’s order.

Following hearings on a rule to show cause, the circuit court found husband in contempt of court by

order entered on April 16, 2019 (“contempt order”). To purge the contempt, the circuit court ordered husband

to deliver to wife all the items delineated in the pendente lite order “by no later than March 5, 2019 at 4:00

p.m.” and also to disclose to wife “the location of any and all funds previously contained” in any previous

bank account of the partnership “that is now closed.”4 The contempt order also included provisions in the

event that wife was not able to obtain all the required information.

The parties aver that a trial is scheduled for March 24-26, 2021.

Petition for Writ of Prohibition

Petitioners argue that the circuit court’s pendente lite and contempt order infringe upon their statutory

rights under Code § 50-73.99 to participate in the management and conduct of the partnership. According to

petitioners, prohibition directed to the circuit court is appropriate in this matter because the circuit court has

acted beyond its jurisdiction by essentially dictating the management of the partnership and foreclosing

husband from his statutory right to participate in the management of the partnership. In petitioners’ view,

husband must forgo statutory rights conferred upon him as a partner to comply with the circuit court’s orders

and the partnership “suffers detriment” without the benefit of husband’s input in the business. Petitioners ask

this Court to prohibit the circuit court from exercising jurisdiction over them in the pending divorce

proceedings, and to enjoin enforcement of the pendente lite and contempt order.

Respondent and wife argue that this Court does not have jurisdiction in this matter because the

challenged orders are not final orders. They further contend that prohibition does not lie because the circuit

court has subject matter jurisdiction in the pending divorce proceedings; thus, it has the statutory authority to

4 The circuit court stated that it would issue a capias for husband if he did not comply. -3- enter orders in those proceedings. Finally, respondent and wife note that petitioners have an adequate remedy

at law.

Analysis

“Before the merits of this case can be considered, [this Court] must determine whether it has

jurisdiction.” Guan v. Ran, 70 Va. App. 153, 155 (2019) (quoting Minor v. Commonwealth, 66 Va. App.

728, 738 (2016)). This Court’s jurisdiction presents a question of law, which we review de novo. Id. at 156.

Respondent and wife contend that this Court lacks jurisdiction because petitioners seek to enjoin enforcement

of orders that are not final in the circuit court. They assert that because the challenged orders are not final

orders, we do not have subject matter jurisdiction to act on the petition. We disagree.

“Subject matter jurisdiction is the authority granted through constitution or statute to adjudicate a

class of cases or controversies.” Martinez v. Commonwealth, 296 Va. 387, 388 (2018) (quoting Gray v.

Binder, 294 Va. 268, 275 (2017)).

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