Jacob F. Chaney v. Julia L. Karabaic-Chaney

CourtCourt of Appeals of Virginia
DecidedJanuary 14, 2020
Docket0859192
StatusPublished

This text of Jacob F. Chaney v. Julia L. Karabaic-Chaney (Jacob F. Chaney v. Julia L. Karabaic-Chaney) 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
Jacob F. Chaney v. Julia L. Karabaic-Chaney, (Va. Ct. App. 2020).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, Russell and Senior Judge Clements Argued at Richmond, Virginia PUBLISHED

JACOB F. CHANEY OPINION BY v. Record No. 0859-19-2 JUDGE MARY GRACE O’BRIEN JANUARY 14, 2020 JULIA L. KARABAIC-CHANEY

FROM THE CIRCUIT COURT OF CHESTERFIELD COUNTY Timothy J. Hauler, Judge

Jessica C. Boutwell (CowanGates, on brief), for appellant.

Aubrey H. Brown, III (Dimitrios E. Karles; Parker, Pollard, Wilton & Peaden, PC, on brief), for appellee.

Julia L. Karabaic-Chaney (“wife”) and Jacob F. Chaney (“husband”) married June 16, 2012,

and separated May 9, 2017. Wife subsequently filed a complaint for divorce and requested

equitable distribution, spousal support, child support, and attorney’s fees. Husband’s responsive

pleading did not include a counterclaim for divorce or allege wife’s adultery as an affirmative

defense. Because husband did not raise the issue of adultery in his answer, wife filed a motion in

limine asking the court to prohibit husband from introducing any evidence of her alleged adultery.

The court granted the motion excluding all evidence of wife’s adultery “for any purpose at any

deposition, hearing[,] or trial.”

The parties proceeded by de bene esse deposition on the issues of equitable distribution and

spousal support. Husband and wife’s depositions took place December 5, 2018, and the court heard argument on all issues except child support on December 21, 2018.1 It received additional

testimony from the parties on January 31, 2019. The court subsequently granted wife a divorce

based on a one-year separation pursuant to Code § 20-91(A)(9)(a), determined the equitable

distribution of property, ordered husband to pay child support, and awarded wife spousal support

“in the amount of $45,000.00 payable over five years in monthly installments of $750 per month”

with “[t]he right to receive future spousal support . . . reserved to [wife] upon motion made before

the expiration of the five[-]year period.”

On appeal, husband assigns error to the court’s spousal support ruling. He contends that the

court should have allowed him to introduce evidence of wife’s adultery for consideration under

Code § 20-107.1(E). He also argues that the evidence was insufficient to warrant spousal support

and that the court erred in determining wife’s right to request future modification of the award.

ANALYSIS

Appellate courts “review a trial court’s decision to admit or exclude evidence using an abuse

of discretion standard and, on appeal, will not disturb a trial court’s decision to [exclude] evidence

absent a finding of abuse of that discretion.” Harman v. Honeywell Int’l, Inc., 288 Va. 84, 92

(2014) (quoting John Crane, Inc. v. Jones, 274 Va. 581, 590 (2007)). However, “a trial court ‘by

definition abuses its discretion when it makes an error of law.’” Shooltz v. Shooltz, 27 Va. App.

264, 271 (1998) (quoting Koon v. United States, 518 U.S. 81, 100 (1996)). This appeal initially

requires us to review the court’s decision to exclude evidence from its consideration of spousal

support under Code § 20-107.1(E). To conduct this review, we also must determine whether the

court properly interpreted the language of Code § 20-107.1(E) specifying the circumstances and

factors courts must consider in awarding spousal support. “[W]e review the trial court’s statutory

1 On December 14, 2018, husband filed a written proffer of facts for the court to consider in determining whether to award wife spousal support under Code § 20-107.1(E). This proffer included allegations to support his claim that wife committed adultery during the marriage. -2- interpretations and legal conclusions de novo.” Navas v. Navas, 43 Va. App. 484, 487 (2004)

(quoting Sink v. Commonwealth, 28 Va. App. 655, 658 (1998)).

Code § 20-107.1 authorizes a court to order spousal support after considering numerous

requisite factors. See Weizenbaum v. Weizenbaum, 12 Va. App. 899, 903 (1991). See also Ray v.

Ray, 4 Va. App. 509, 513 (1987) (“A review of all the factors contained in Code § 20-107.1 is

mandatory.”). “When a court awards spousal support based upon due consideration of the factors

enumerated in Code § 20-107.1, as shown by the evidence, its determination ‘will not be disturbed

except for a clear abuse of discretion.’” Dodge v. Dodge, 2 Va. App. 238, 246 (1986) (quoting

Thomasson v. Thomasson, 225 Va. 394, 398 (1983)).

“An abuse of discretion . . . exists if the trial court fails to consider the statutory factors

required to be part of the decisionmaking process.” Congdon v. Congdon, 40 Va. App. 255, 262

(2003). “In determining spousal support, the . . . court must consider all factors contained in Code

§ 20-107.1; failure to do so constitutes reversible error.” Rowe v. Rowe, 24 Va. App. 123, 139

(1997). See also Keyser v. Keyser, 7 Va. App. 405, 414-15 (1988) (reversing denial of spousal

support where the court considered only the marriage’s short duration and wife’s “good . . .

financial condition” rather than all factors under Code § 20-107.1(E)).

Code § 20-107.1(E) provides that “[t]he court, in determining whether to award support and

maintenance for a spouse, shall consider the circumstances and factors which contributed to the

dissolution of the marriage, specifically including adultery and any other ground for divorce.” The

statute enumerates thirteen specific factors the court must consider when awarding spousal support.

Code § 20-107.1(E)(1)-(13). Code § 20-107.1(E)(13) reiterates the direction that the court consider

“other factors, including . . . the circumstances and factors that contributed to the dissolution [of the

marriage], specifically including any ground for divorce, as are necessary to consider the equities

between the parties.”

-3- Here, wife asserts that the court correctly excluded evidence of her adultery in her spousal

support claim because husband did not allege adultery as a ground for divorce or as an affirmative

defense. In support of this argument, wife relies on Code § 20-107.1(B). When granting a divorce

on adultery grounds, a court cannot award support to the adulterous spouse unless denying support

“would constitute a manifest injustice, based upon the respective degrees of fault during the

marriage and the relative economic circumstances of the parties.” Code § 20-107.1(B).

Adultery is a statutory ground for divorce. Code § 20-91(A)(1). However, we disagree with

wife’s contention that a court may not consider adultery evidence in determining spousal support

unless adultery was expressly pled. Here, husband does not contend that evidence of wife’s

adultery was relevant and admissible to establish a ground for divorce; he acknowledges that he did

not file a counterclaim alleging grounds for divorce and that he did not assert adultery as an

affirmative defense to her complaint. Rather, husband argues that the court should have permitted

him to present evidence of wife’s adultery because Code § 20-107.1(E) requires the court to

consider “the circumstances and factors which contributed to the dissolution of the marriage,

specifically including adultery and any other ground for divorce.” Code § 20-107.1(E) (emphasis

added). Accordingly, he argues that the court’s pretrial ruling precluding him from presenting

evidence of wife’s adultery, a “factor[] which contributed to the dissolution of the marriage,” was in

error.

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Related

Koon v. United States
518 U.S. 81 (Supreme Court, 1996)
John Crane, Inc. v. Jones
650 S.E.2d 851 (Supreme Court of Virginia, 2007)
Campbell v. Harmon
628 S.E.2d 308 (Supreme Court of Virginia, 2006)
Crawford v. Haddock
621 S.E.2d 127 (Supreme Court of Virginia, 2005)
Kirby v. Commonwealth
653 S.E.2d 600 (Court of Appeals of Virginia, 2007)
Navas v. Navas
599 S.E.2d 479 (Court of Appeals of Virginia, 2004)
Congdon v. Congdon
578 S.E.2d 833 (Court of Appeals of Virginia, 2003)
Hughes v. Hughes
531 S.E.2d 645 (Court of Appeals of Virginia, 2000)
Sink v. Commonwealth
507 S.E.2d 670 (Court of Appeals of Virginia, 1998)
Thomas C. Shooltz v. Jane Hoffman Shooltz
498 S.E.2d 437 (Court of Appeals of Virginia, 1998)
Mary Anne Rowe v. Charles S. Rowe
480 S.E.2d 760 (Court of Appeals of Virginia, 1997)
Ray v. Ray
358 S.E.2d 754 (Court of Appeals of Virginia, 1987)
Dodge v. Dodge
343 S.E.2d 363 (Court of Appeals of Virginia, 1986)
Barnes v. Barnes
428 S.E.2d 294 (Court of Appeals of Virginia, 1993)
Thomasson v. Thomasson
302 S.E.2d 63 (Supreme Court of Virginia, 1983)
Weizenbaum v. Weizenbaum
407 S.E.2d 37 (Court of Appeals of Virginia, 1991)
Keyser v. Keyser
374 S.E.2d 698 (Court of Appeals of Virginia, 1988)
Commonwealth v. White
799 S.E.2d 494 (Supreme Court of Virginia, 2017)
MacDougall v. Levick
805 S.E.2d 775 (Supreme Court of Virginia, 2017)

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