In the Matter of the Marriage of: Jenny Lynn Veca & Aaron Keyes Prichard

CourtCourt of Appeals of Washington
DecidedApril 30, 2019
Docket35685-0
StatusUnpublished

This text of In the Matter of the Marriage of: Jenny Lynn Veca & Aaron Keyes Prichard (In the Matter of the Marriage of: Jenny Lynn Veca & Aaron Keyes Prichard) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Marriage of: Jenny Lynn Veca & Aaron Keyes Prichard, (Wash. Ct. App. 2019).

Opinion

FILED APRIL 30, 2019 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

In the Matter of the Marriage of: ) No. 35685-0-III ) JENNY LYNN VECA, ) ) Appellant, ) ) UNPUBLISHED OPINION and ) ) AARON KEYES PRICHARD, ) ) Respondent. )

PENNELL, A.C.J. — Jenny Lynn Veca appeals several aspects of a final parenting

plan, issued in connection with Ms. Veca’s petition to dissolve her marriage to Aaron

Keyes Prichard. We reject the majority of Ms. Veca’s claims, but remand on two issues.

The trial court shall amend the parenting plan as follows: (1) conform the Skype call

schedule (Section 14(A)) to the trial court’s oral ruling, and (2) reallocate travel expenses

(Section 12) according to the parties’ basic child support obligations. The trial court’s

orders on review are otherwise affirmed.

FACTS

Jenny Lynn Veca and Aaron Keyes Prichard were married in 2004 and have two

children. The parties’ relationship has been tumultuous. Over the years, Ms. Veca has No. 35685-0-III In re Marriage of Veca & Prichard

made numerous domestic violence allegations against Mr. Prichard. None of these

allegations have resulted in criminal convictions for assault or related conduct.

In 2014, Ms. Veca filed for dissolution of the marriage in Benton County Superior

Court. During the pendency of the proceedings, Ms. Veca moved to Nevada with the

parties’ children. Trial was held in 2017.

The trial process was long and contentious. At the end of the proceedings, the

trial court found Ms. Veca not credible. The court disagreed with Ms. Veca’s allegations

that Mr. Prichard had a history of domestic violence. Thus, the court did not restrict Mr.

Prichard’s decision-making authority or residential time pursuant to RCW 26.09.191(1)

and (2). The court expressed displeasure with Ms. Veca’s unilateral decision to move the

children to Nevada. The court also found Ms. Veca had used conflict in ways that

endangered the psychological development of her children. Nevertheless, the trial court

determined Ms. Veca was a good parent and that the children would suffer if removed

from her primary care. The court issued a detailed parenting plan, addressing the

specifics of the children’s residential schedules along with an apportionment of travel

expenses. The trial court warned that the parenting plan could be subject to modification

based on future misconduct.

Ms. Veca appeals.

2 No. 35685-0-III In re Marriage of Veca & Prichard

ANALYSIS

Ms. Veca assigns several errors to the trial court’s parenting plan. Our review is

governed by the abuse of discretion standard. In re Marriage of Caven, 136 Wn.2d 800,

806, 966 P.2d 1247 (1998). Because the majority of Ms. Veca’s claims are factual, our

review is focused on the trial record, including the transcribed report of proceedings.

However, much of the trial proceedings has not been included in the record on appeal.

The only trial testimony before us comes from Ms. Veca and Mr. Prichard. As the

appellant, Ms. Veca was responsible for arranging transcription of those portions of the

trial court proceedings necessary to present the issues on appeal. RAP 9.2(b). Because

many of the trial court’s findings appear to have been based on the testimony of witnesses

other than Ms. Veca and Mr. Prichard, our review of the trial court’s findings is especially

deferential.

Domestic violence limitations—RCW 26.09.191

A trial court is required to impose restrictions on decision-making and residential

time when a parent is found to have a history of domestic violence. RCW 26.09.191(1)-

(2). While the statute governing domestic violence restrictions is written in mandatory

terms, the trial court retains “discretion to determine whether the evidence presented

meets the requirements of” the statute. In re Parenting & Support of L.H., 198 Wn. App.

3 No. 35685-0-III In re Marriage of Veca & Prichard

190, 194, 391 P.3d 490 (2016). “Mere accusations, without proof, are not sufficient to

invoke the restrictions under the statute.” Caven, 136 Wn.2d at 809.

Ms. Veca recognizes the applicability of a trial court’s fact-finding authority under

RCW 26.09.191. Nevertheless, she argues that the trial court was required to make a

finding of domestic violence against Mr. Prichard based on the existence of prior no-

contact orders that had been issued against Mr. Prichard. 1

Ms. Veca’s arguments appear to rest on a theory of collateral estoppel. Collateral

estoppel, or issue preclusion, bars relitigation of an issue that was previously decided

between the two parties to a case during a prior court proceeding. Christensen v. Grant

County Hosp. Dist. No. 1, 152 Wn.2d 299, 306, 96 P.3d 957 (2004). A party seeking

application of collateral estoppel must establish that:

(1) the issue decided in the earlier proceeding was identical to the issue presented in the later proceeding; (2) the earlier proceeding ended in a judgment on the merits; (3) the party against whom collateral estoppel is asserted was a party to, or in privity with a party to, the earlier proceeding; and (4) application of collateral estoppel does not work an injustice on the party against whom it is applied.

1 Ms. Veca also claims that the court should have relied on a prior finding of domestic violence by California’s Child Welfare Services (CWS). The record on review contains no such formal finding. Instead, the document cited by Ms. Veca is a “Safety Plan” with a handwritten note stating, “DV exists between the parents. Fa[ther] is violent towards the mother and the police has [sic] been called.” Clerk’s Papers at 479. The Safety Plan contains a notice that it is designed to ensure safety “while CWS completes this investigation.” Id. The document simply does not represent a formal finding of domestic violence.

4 No. 35685-0-III In re Marriage of Veca & Prichard

Id. at 307. The applicability of issue preclusion is a legal matter reviewed de novo.

Id. at 305.

Ms. Veca cites no authority indicating collateral estoppel applies in the current

context. At least with respect to restrictions on residential time under RCW 26.09.191(2),

the legislature has indicated that collateral estoppel does not apply to prior protection

orders issued between the parties. RCW 26.09.191(2)(n). Instead, “[t]he weight given to

the existence of a protection order issued . . . is within the discretion of the court.” Id.

The legislature has not indicated whether collateral estoppel should apply to prior

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Related

Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
State v. Dominguez
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In Re the Marriage of Velickoff
968 P.2d 20 (Court of Appeals of Washington, 1998)
In Re Parentage of Schroeder
22 P.3d 1280 (Court of Appeals of Washington, 2001)
In re the Marriage of Caven
966 P.2d 1247 (Washington Supreme Court, 1998)
Christensen v. Grant County Hospital District No. 1
96 P.3d 957 (Washington Supreme Court, 2004)
State v. Solis-Diaz
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Brester v. Bollenbacher
106 Wash. App. 343 (Court of Appeals of Washington, 2001)
In re the Paternity of Hewitt
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