In Re: Derek Wayne Fowler and Rebecca Ainley Fowler Applying for Intrafamily Adoption of: H.S.A.

CourtLouisiana Court of Appeal
DecidedFebruary 28, 2024
Docket55,622-JAC
StatusPublished

This text of In Re: Derek Wayne Fowler and Rebecca Ainley Fowler Applying for Intrafamily Adoption of: H.S.A. (In Re: Derek Wayne Fowler and Rebecca Ainley Fowler Applying for Intrafamily Adoption of: H.S.A.) 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
In Re: Derek Wayne Fowler and Rebecca Ainley Fowler Applying for Intrafamily Adoption of: H.S.A., (La. Ct. App. 2024).

Opinion

Judgment rendered February 28, 2024. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,622-JAC

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

IN RE: DEREK WAYNE FOWLER AND REBECCA AINLEY FOWLER APPLYING FOR INTRAFAMILY ADOPTION OF: H.S.A.

Appealed from the Fifth Judicial District Court for the Parish of West Carroll, Louisiana Trial Court No. 339

Honorable Clay Hamilton, Judge

NICHOLAS AARON DABBS In Proper Person, Intervenor-Appellant

AMY COATH JOHNSON Counsel for Appellees, Derek Wayne Fowler and Rebecca Ainley Fowler

Before PITMAN, STONE, and ROBINSON, JJ. PITMAN, C. J.

Intervenor-Appellant Nicholas Aaron Dabbs appeals the final decree

of adoption granted by the trial court in favor of Petitioners-Appellees Derek

Wayne Fowler and Rebecca Ainley Fowler. For the following reasons, we

affirm.

FACTS

On June 19, 2023, the Fowlers filed a petition for stepparent adoption.

They stated that Rebecca is the biological mother of H.S.A., whose date of

birth is February 10, 2015; Rebecca and Derek married on April 22, 2023;

Derek wished to adopt H.S.A.; and Rebecca consented to the adoption.

They noted that Dabbs is the biological father of H.S.A., Rebecca has sole

custody and Dabbs was awarded visitation. They stated that Dabbs was

arrested in January 2023 for failure to pay child support; he pled guilty in

March 2023; and he is in arrears in the amount of $17,538.55. They stated

that Dabbs has not paid child support or contacted H.S.A. for a period of

over six months; and, therefore, his consent to the adoption could be

dispensed with. They argued that the adoption was in the best interest of the

child.

On June 26, 2023, Dabbs filed a response and stated that he opposed

the adoption. He noted that he paid monthly child support since October

2018, except for 13 months when he did not pay. He stated that child

support is taken out of his paycheck, and he pays extra each month for the

arrears. He also alleged that he tried to communicate with and see H.S.A.

but that Rebecca moved, changed her phone number and refused to allow

visitation. A hearing was held on August 14, 2023. Dabbs stated that he

opposed the adoption because there was an ongoing custody and contempt

matter in another parish. Counsel for the Fowlers replied that there was a

final judgment in the custody matter and that Dabbs filed the rule for

contempt after the adoption was initiated in an effort to derail the adoption.

Counsel for the Fowlers then argued that Dabbs’s consent to the adoption

was not required because two conditions of La. Ch. C. art. 1245 had been

met—a period of six months without paying court-ordered child support and

a period of six months with no contact.

Rebecca testified that Dabbs was first ordered to pay child support in

March 2017, retroactive to July 2015; that she did not receive a child support

payment until October 2018; and that Dabbs was over $15,000 behind in

child support payments. She testified that she received sole custody of

H.S.A. in 2019, that Dabbs had visitation and that H.S.A. last saw Dabbs in

December 2018. She noted that the last day H.S.A. was in his custody, he

was arrested for robbing a house. She testified that in early 2019, Dabbs

began contacting her about visitation and threatened her on Facebook, so she

did not respond. She noted that she did not hear from Dabbs for over four

years until he initiated new custody proceedings. She stated that their

custody arrangement was not changed and that she was not found to be in

contempt of court. She noted that Dabbs was ordered to submit to a drug

test before obtaining any visitation and that he did not submit to the test.

She stated that H.S.A. does not know who Dabbs is, and she wished for her

husband to adopt H.S.A. On cross-examination, Rebecca testified that she is

now receiving child support payments. She noted that she changed her

phone number, that Dabbs has her new phone number and that she never 2 blocked Dabbs’s phone number. She stated that she did block him and his

family on Facebook but that they could communicate with her by phone.

Dabbs testified that he began making child support payments in

October 2018. He stated that prior to this time, he submitted payments to

Child Support Enforcement Services, but his payments were returned. He

admitted that he had been arrested for nonpayment of child support and that

he was sentenced to probation. He testified that he had not seen H.S.A.

since December 2018 because Rebecca kept her from him. He stated that

H.S.A. was not with him when he committed the crime of burglary or when

he was arrested for it. He alleged that he did take a drug test in a timely

manner. He agreed that Rebecca had reasons to be concerned about H.S.A.

being in his care. He stated that he last contacted Rebecca in October 2022

by text message but that she never responded. He recalled that in a

deposition he stated that on two occasions he went at least 18 months

without contacting Rebecca about H.S.A.

The trial court found that the Fowlers established that there was a

period in excess of six months that Dabbs failed to pay child support. It

noted that Dabbs was currently on probation for failing to pay child support

and was in arrears in the amount of $17,538.55. It also found, by Dabbs’s

own admission, that he failed to communicate with H.S.A. for

approximately four years. The court stated that this failure was not due to

any actions of Rebecca. Dabbs interrupted the trial court to state that he did

try to go to court over visitation but that his court dates were continued due

to the pandemic and then his attorney was disbarred. The trial court

responded that his failure to pay child support was more than sufficient to

3 determine that his consent was not required for this adoption. The trial court

stated that it would issue a judgment granting the intrafamily adoption.

On August 17, 2023, Dabbs filed a letter to the trial court and

requested a new trial or appeal. He alleged that his due process rights were

violated because he was never offered counsel, which resulted in him not

having an adequate defense. He also argued that the trial should have been

held in Ouachita Parish, where there was ongoing litigation about custody.

The trial court denied the motion for new trial.

On August 23, 2023, the trial court filed a final decree of adoption. It

stated that the Fowlers met their burden of proof by clear and convincing

evidence that Dabbs failed to pay court-ordered child support for a period in

excess of six months and that he failed to establish just cause for his failure

to do so. Therefore, it found that Dabbs’s consent was not required. It

determined that adoption was in the best interest of the child, terminated

Dabbs’s parental rights and entered a final decree of adoption.

Dabbs appeals.

DISCUSSION

Venue

Dabbs argues that the Fifth Judicial District Court (“JDC”) was not

the proper venue for the adoption.

The Fowlers argue that the Fifth JDC is the proper venue pursuant to

La. Ch. C. art. 1180 because it includes the parish that is the domicile of the

petitioners. They contend that the fact that custody litigation took place in

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Related

In Re Morris
892 So. 2d 739 (Louisiana Court of Appeal, 2005)
Boudreaux v. STATE, DOTD
815 So. 2d 7 (Supreme Court of Louisiana, 2002)
In re Puckett
137 So. 3d 1264 (Louisiana Court of Appeal, 2014)
In re D.C.M.
170 So. 3d 165 (Louisiana Court of Appeal, 2013)
In re Adoption of C.S.
505 So. 2d 1010 (Louisiana Court of Appeal, 1987)

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Bluebook (online)
In Re: Derek Wayne Fowler and Rebecca Ainley Fowler Applying for Intrafamily Adoption of: H.S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-derek-wayne-fowler-and-rebecca-ainley-fowler-applying-for-lactapp-2024.