In re The Marriage of Jenkins

CourtCourt of Appeals of Iowa
DecidedJanuary 25, 2023
Docket22-0656
StatusPublished

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

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In re The Marriage of Jenkins, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0656 Filed January 25, 2023

IN RE THE MARRIAGE OF JESSICA RAY JENKINS AND TYREL JAMES JENKINS

Upon the Petition of JESSICA RAY JENKINS, Petitioner-Appellee,

And Concerning TYREL JAMES JENKINS, Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Bremer County, James Drew, Judge.

A former spouse appeals a decree of dissolution of marriage. AFFIRMED

AS MODIFIED AND REMANDED.

Terry D. Parsons of Olsen & Parsons Law Firm, Cedar Falls, for appellant.

Andrew B. Howie of Shindler, Anderson, Goplerud & Weese, P.C., West

Des Moines, and Karen Thalacker of Correll, Sheerer, & Benson, Waverly, for

appellee.

Considered by Vaitheswaran, P.J., and Greer and Schumacher, JJ. 2

SCHUMACHER, Judge.

Tyrel Jenkins appeals the district court’s dissolution decree following his

failure to appear at trial. He contends the court’s decree exceeds the permissible

scope of relief, is not in the children’s best interest, and places too much authority

over visitation in the hands of his ex-wife, Jessica, and the parties’ children. He

also claims the court failed to follow the procedures set out in Iowa Code

chapter 598 (2021). We find Tyrel did not preserve error on his challenges

involving chapter 598. We also find the court did not exceed the permissible scope

of relief by granting Jessica sole legal custody. We determine the court should

have set a defined visitation schedule that does not delegate decision making

authority on Tyrel’s visitation to Jessica or the children. Finally, we determine the

conditions on Tyrel’s visits concerning substance use and testing should be

eliminated. Accordingly, we affirm as modified and remand.

I. Background Facts & Proceedings

Jessica and Tyrel married in 2005. They share four children, ages sixteen,

fourteen, eleven, and ten at the time of trial. Tyler has been previously convicted

of domestic abuse assault. The children lived with Jessica since the entry of a no-

contact order (NCO) in January 2021 that prohibited Tyrel from contacting her.1

The incident underpinning the NCO resulted in Tyrel again being criminally

charged with domestic abuse assault, although the outcome of that charge was

pending at the time of the dissolution trial. There were repeated violations of the

1The terms of the NCO were modified shortly after it was put in place to allow the defendant access to some parts of the familial property. But the NCO was modified again in June 2021 based on an incident where Tyrel entered the familial home and obtained a handgun. The incident resulted in a contempt filing. 3

NCO. At trial, Jessica agreed that Tyrel had violated the NCO almost more times

than she could count. On one of Jessica’s audio exhibits, Tyrel states to Jessica,

“Fuck you and your restraining order. How good would it do if I fucking killed you

right now?” Additional audio recordings admitted at trial demonstrate a pattern of

abuse perpetrated by Tyrel, including one incident in 2018 where one of the

children called the authorities because Tyrel was physically harming Jessica. An

additional criminal charge was filed as a result of the violations.

Jessica petitioned to dissolve the marriage on April 16, 2021. Her original

petition sought joint legal custody and physical care. Tyrel’s acceptance of service

was filed May 20; he filed an answer as a self-represented litigant on June 6. His

answer did not specify what relief he was requesting. This is the only document

Tyrel filed before trial.2

Trial was held March 17, 2022. Tyrel failed to appear, resulting in the court

finding him in default.3 Jessica testified and submitted exhibits. Her testimony

mainly focused on Tyrel’s alcohol abuse and his perpetration of domestic violence

against her. Based on her testimony, the court allowed Jessica to amend her

petition to request sole legal custody.

The court entered the dissolution decree on the same day as trial. 4 It

granted Jessica sole legal custody and physical care. The court ordered that Tyrel

2 Contrary to the pretrial order, Tyrel did not file a financial affidavit, witness list, or proposed exhibits. 3 In another example of a violation of the NCO, Tyrel contacted Jessica the day

before the trial and told her to advise her attorney to stop sending him emails, that the trial was a joke, and that he could get the trial continued without any problems. 4 The district court ordered Jessica’s counsel to submit a proposed decree

following trial. 4

could visit the children once a week.5 But the decree provided that the children

were not required to participate in the visits. Tyrel was forbidden from consuming

any alcohol or illegal substances prior to or during the visits. Jessica was permitted

to request testing to prove sobriety. If he consumed those substances, the

visitation would immediately cease and the children would be returned to Jessica.

On April 14, Tyrel moved to set aside the default dissolution decree

pursuant to Iowa Rule of Civil Procedure 1.977. He filed a notice of appeal the

next day. The district court found that it lacked jurisdiction to rule on his motion

due to the notice of appeal.6

II. Discussion

Tyrel raises several claims on appeal. First, he contends the visitation

framework limits his visits and unduly puts the children in the middle of the parents’

disagreements. He also claims the court exceeded the permissible relief by

allowing Jessica to amend her petition at trial. Tyrel further claims the decree did

not meet the requirements of Iowa Code chapter 598, resulting in a record

insufficient for review.

A. Error Preservation

Jessica contends Tyrel has failed to preserve his claims because he did not

object at trial. “It is a fundamental doctrine of appellate review that issues must

ordinarily be both raised and decided by the district court before we will decide

5 While the decree also set out a holiday schedule, the decree also provided that the children were not required to see their father on those holidays. 6 Jessica asks us to find Tyrel cannot renew his motion to set aside the decree

following this appeal. We decline to do so, as Tyrel’s decision to renew the motion is hypothetical. 5

them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002). She

argues because Tyrel failed to appear at trial, he could not preserve error on any

specific issues. However, “a defaulting party to a dissolution proceeding may seek

appellate review on the merits. But, our de novo review will generally be limited to

(1) scope of relief granted, and (2) equities of the decree as determined by an

examination of the entire record made at trial.” In re Marriage of Huston, 263

N.W.2d 697, 700 (Iowa 1978). Tyrel contests the visitation and custody provisions

of the decree, asserting it wrongly restricts his time with the children. He also

claims the relief exceeded the scope sought in the original petition. Thus, those

claims fall in the exception to our standard error preservation rules. However,

Tyrel’s claims alleging the court failed to comply with chapter 598 are procedural.

As a result, those procedural claims are not preserved, and we do not consider

them.

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Related

Lamansky v. Lamansky
207 N.W.2d 768 (Supreme Court of Iowa, 1973)
Smith v. Smith
142 N.W.2d 421 (Supreme Court of Iowa, 1966)
In Re the Marriage of Daniels
568 N.W.2d 51 (Court of Appeals of Iowa, 1997)
In Re the Marriage of Fite
485 N.W.2d 662 (Supreme Court of Iowa, 1992)
In Re the Marriage of Okland
699 N.W.2d 260 (Supreme Court of Iowa, 2005)
Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
In Re the Marriage of Huston
263 N.W.2d 697 (Supreme Court of Iowa, 1978)
In Re the Marriage of Rykhoek
525 N.W.2d 1 (Court of Appeals of Iowa, 1994)
In Re the Marriage of Smith
471 N.W.2d 70 (Court of Appeals of Iowa, 1991)
In re the Marriage of Stephens
810 N.W.2d 523 (Court of Appeals of Iowa, 2012)

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