In re Marriage of R.K. and L.K.

CourtCourt of Appeals of Kansas
DecidedAugust 29, 2025
Docket126759
StatusUnpublished

This text of In re Marriage of R.K. and L.K. (In re Marriage of R.K. and L.K.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Marriage of R.K. and L.K., (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 126,759

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

In the Matter of the Marriage of

R.K., Appellant,

and

L.K., Appellee.

MEMORANDUM OPINION

Appeal from Johnson District Court; K. CHRISTOPHER JAYARAM, judge. Submitted without oral argument. Opinion filed August 29, 2025. Affirmed.

Jeffrey Leiker, of Leiker Law Office, P.A., of Overland Park, for appellant father.

Sarah Carmody, of Sarah Carmody Law, LLC, of Overland Park, for appellee mother.

Valerie L. Moore, guardian ad litem, of Lenexa.

Before CLINE, P.J., MALONE and PICKERING, JJ.

PER CURIAM: This case arises out of a contentious postdivorce proceeding in which Father sought to modify the court-ordered parenting plan. Father challenges several procedural rulings on appeal, including sanctions and filing limitations the district court imposed on Father and his counsel and the court's decision not to sequester the case manager at trial. He also claims the district court abused its discretion when evaluating the facts for its ruling.

1 After careful examination of the record, we find Father has failed to preserve his constitutional objections or establish the district court abused its discretion in reaching its decision. We also note the court provided Father notice and an opportunity to object to its proposed impositions of sanctions and filing restrictions—to which Father did not avail himself. We therefore affirm the court's decisions.

FACTUAL AND PROCEDURAL BACKGROUND

Father and Mother, parents to four children, divorced in November 2018. A few months before issuing the divorce decree, the district court appointed a case manager to make recommendations about custody, parenting time, psychological evaluations, personal conduct, financial issues, and educational needs of the children. Following a three-day trial in December 2019, the district court entered a parenting plan where it awarded temporary sole custody to Mother.

At that time, the district court also instituted a plan where Father would receive joint legal custody if he completed three phases: (1) intensive therapy and supervised time; (2) monitored access and modified legal custody (Mother would receive sole legal custody for medical decisions and the parties would share joint legal custody for educational decisions) after Father "genuinely demonstrated a true understanding and self-awareness of his past destructive behaviors" and "is prepared to co-parent productively with Mother"; and (3) continued monitored access and modified legal custody (joint legal custody for medical and educational decisions along with expanded parenting access for Father) if Father successfully prevailed on court ordered tasks. Father did not file a motion to reconsider nor did he appeal this order.

About a year later, Father, who was still in phase 1, filed a motion to accelerate the phased parenting plan and immediately transition the parties to the final phase. The parties litigated issues surrounding this motion over the next year, with Father filing three

2 motions for "'emergency relief'" in late 2021. At the December 9, 2021 hearing on these filings, the district court stated Father was raising issues which had already been decided and his pleadings were meritless and improperly filed to unnecessarily increase the cost of the matter. It then noted it was inclined to issue sanctions against Father and his counsel and gave Father seven days to brief why the court should not issue sanctions under K.S.A. 60-211 to Father and his counsel.

The district court entered a journal entry on January 7, 2022, ordering sanctions. In this journal entry, the district court noted the "extensive" court file in this "high conflict" matter which contained almost 250 court filings. The court found none of Father's "'emergency requests'" were submitted for a proper purpose or had a good-faith factual foundation. Instead, the court found the filings were "yet another effort by [Father] to needlessly increase costs to the parties, gain strategic advantages with respect to his own parenting time, and to re-litigate issues that were, in various respects, fully and finally adjudicated in 2019 or earlier or were so remote in time that they simply cannot constitute an 'emergency.'" The court also found Father's counsel had recited data and terms of what was intended to be a sealed document that contained nondisclosure provisions "in direct contravention of the parties' prior agreement and of the Court's prior Order."

The district court ordered Father to pay Mother's, the GAL's, and the case manager's attorney fees associated with addressing Father's three motions, along with ordering Father and Father's counsel to pay $2,500 each to the clerk of the court. After reviewing affidavits from counsel on fees and "[n]oting no objections from [Father]," the court ordered Father to pay $3,300 to Mother's counsel, $2,800 to the GAL, and $2,623.96 to the case manager.

Father's problematic filings, however, did not subside. In June 2022, the district court imposed "provisional temporary" filing restrictions on Father and ordered the clerk

3 of the district court not to accept any pleadings submitted by Father or his counsel, absent express written consent from the district court. The ruling discussed how Father filed "voluminous and extensive motions and other pleadings." For example, it noted that 60 filings occurred in a three-and-a-half-month span. Most of those pleadings were from Father or filed in response to his filings. Again, the court permitted Father to file objections to the filing restrictions before the restrictions took effect and stated it would rule on any such objections. The record reveals no filings by Father regarding these proposed filing restrictions.

In early 2023, the district court again sanctioned Father and his counsel under K.S.A. 60-211 for moving to compel the GAL to gather records. According to the court, this motion sought to "make an 'end run' around the discovery deadline." The court ordered Father to pay $3,500 and his counsel to pay $5,000 to the clerk of the court. This order also stated the court had notified the parties it was contemplating sanctions regarding Father's motion and it had invited a briefing schedule on the issues.

After a trial in April 2023, the district court filed its final judgment and court- ordered parenting plan, wherein it concluded Mother should have sole legal and physical custody of the children and granted Father specified visitation times. Father appealed this decision "including all associated rulings and orders."

REVIEW OF FATHER'S APPELLATE CHALLENGES

I. Did the district court violate Father's procedural due process rights when it imposed filing restrictions and assessed sanctions against Father and his counsel?

Father first argues the district court infringed on his due process rights by restricting his ability to file documents in court and wrongly issuing sanctions against him and his counsel. He claims he was denied meaningful notice about the possible

4 imposition of filing restrictions in violation of his rights under the United States and Kansas Constitutions. He also claims that since no motion for sanctions was filed,

"and the Court did not set forth any reasons, or of what Father was being accused as a violation of K.S.A. 60-211

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