Jamie Cass v. Kevin Charlie Cass

CourtLouisiana Court of Appeal
DecidedNovember 17, 2010
DocketCA-0010-0327
StatusUnknown

This text of Jamie Cass v. Kevin Charlie Cass (Jamie Cass v. Kevin Charlie Cass) 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
Jamie Cass v. Kevin Charlie Cass, (La. Ct. App. 2010).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

10-327

JAMIE CASS

VERSUS

KEVIN CHARLIE CASS

**********

APPEAL FROM THE THIRTY-FIFTH JUDICIAL DISTRICT COURT PARISH OF GRANT, NO. 19395 HONORABLE WARREN D. WILLETT, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of John D. Saunders, Oswald A. Decuir, Marc T. Amy, Elizabeth A. Pickett, and Billy Howard Ezell, Judges.

REVERSED AND REMANDED.

Saunders, J., dissents and assigns written reasons.

J. Ogden Middleton, II 1744 White Street Alexandria, LA 71301 (318) 443-4377 COUNSEL FOR DEFENDANT/APPELLANT: Kevin Charlie Cass

David C. Hesser 2820 Jackson Street Alexandria, LA 71301 (318) 542-4102 COUNSEL FOR PLAINTIFF/APPELLEE: Jamie Cass AMY, Judge.

The defendant appeals a judgment of the trial court disallowing him to relocate

to Texas with his minor son and naming the plaintiff as domiciliary parent. For the

following reasons, we reverse and remand.

Factual and Procedural Background

Ms. Jamie Cass, the plaintiff and appellee, and Mr. Kevin Cass, the defendant

and appellant, obtained a judgment of divorce on July 31, 2009. Pursuant to a

consent judgment, the parties shared joint custody of one minor child born of the

marriage. The consent judgment, entered on May 28, 2009, detailed a shared physical

custody schedule and designated Mr. Cass as the domiciliary parent.

The record reveals that Mr. Cass, a Sergeant First Class in the Army, received

orders in early 2009 informing him that he was being transferred from Fort Polk in

Louisiana to Fort Hood in Texas. Mr. Cass asserts that at some time in either April

or May 2009, he informed Ms. Cass, a Lieutenant in the Army, of the transfer order.

On May 29, 2009, Ms. Cass filed an “Objection to Relocation, Rule For Relocation

Evaluation, and Rule For Custody” seeking to prevent Mr. Cass from moving out of

Louisiana with the child until a hearing could be held in addition to requesting that

she be named the domiciliary parent. Mr. Cass answered Ms. Cass’s objection and

filed a rule for a temporary order to relocate.1 On July 29, 2009, the trial court denied

Mr. Cass’s request to temporarily relocate the child to Fort Hood, and a hearing was

set to determine the permanent relocation issue.

Following a three-day hearing, the trial court issued oral reasons for judgment

denying Mr. Cass’s request to relocate, changing domiciliary custody to Ms. Cass,

and denying Mr. Cass’s request to remain in Louisiana as a domiciliary custodian.

1 Included with the rule for a temporary order to relocate were other motions which are not at issue in this appeal, and therefore, will not be discussed herein. A “Judgment on the Rule” was subsequently signed; however, the written judgment

did not contain reference to the trial court’s denial of Mr. Cass’s request to remain in

Louisiana as a domiciliary custodian. Mr. Cass filed a Motion for Entry of

Supplemental Judgment, and on September 10, 2009, the trial court issued a

supplemental judgment reflecting that denial.

Mr. Cass appeals, asserting the trial court erred in: (1) misapplying the

relocation statute and denying his request to relocate; (2) failing to follow the

required analysis in relocation cases; (3) finding that his move to Texas constituted

a change in circumstance warranting a modification of the initial consent judgment;

(4) naming the defendant as the domiciliary parent and refusing to recognize him as

a Louisiana domiciliary; (5) failing to have the child’s in camera interview

transcribed; (6) ignoring the mental health evaluator’s findings; and (7) refusing to

let the mental health evaluator see the minor child to further evaluate emotional

issues.

Discussion

Standard of Review

Mr. Cass first asserts that this court should conduct a de novo review of the

present matter, contending that the trial court: failed to consider the relocation factors

enumerated in La.R.S. 9:355.12; ignored the applicable burden of proof under La.R.S.

9:355.13, and; in making its decision, the trial court relied upon what the child related

to it in an in camera conversation that was not transcribed. He argues that these

alleged failures constitute legal error; therefore, this court is not bound by the

manifest error standard.

2 A parent seeking relocation must prove two things: (1) that the proposed

relocation is in good faith and (2) that the proposed relocation is in the best interest

of the child. La.R.S. 9:355.13. Louisiana Revised Statutes 9:355.12 enumerates

factors the trial court shall consider in deciding a contested relocation, as follows:

(1) The nature, quality, extent of involvement, and duration of the child’s relationship with the parent proposing to relocate and with the nonrelocating parent, siblings, and other significant persons in the child’s life.

(2) The age, developmental stage, needs of the child, and the likely impact the relocation will have on the child’s physical, educational, and emotional development, taking into consideration any special needs of the child.

(3) The feasibility of preserving a good relationship between the nonrelocating parent and the child through suitable visitation arrangements, considering the logistics and financial circumstances of the parties.

(4) The child’s preference, taking into consideration the age and maturity of the child.

(5) Whether there is an established pattern of conduct of the parent seeking the relocation, either to promote or thwart the relationship of the child and the nonrelocating party.

(6) Whether the relocation of the child will enhance the general quality of life for both the custodial parent seeking the relocation and the child, including but not limited to financial or emotional benefit or educational opportunity.

(7) The reasons of each parent for seeking or opposing the relocation.

(8) The current employment and economic circumstances of each parent and whether or not the proposed relocation is necessary to improve the circumstances of the parent seeking relocation of the child.

(9) The extent to which the objecting parent has fulfilled his or her financial obligations to the parent seeking relocation, including child support, spousal support, and community property obligations.

(10) The feasibility of a relocation by the objecting parent.

(11) Any history of substance abuse or violence by either parent,

3 including a consideration of the severity of such conduct and the failure or success of any attempts at rehabilitation.

(12) Any other factors affecting the best interest of the child.

This statute mandates that the trial court consider the enumerated factors;

however, it does not require the court to give preferential consideration to any certain

factor. Curole v. Curole, 02-1891 (La. 10/15/02), 828 So.2d 1094. A trial court’s

determination in a relocation dispute is entitled to great weight and will not be

overturned absent a clear showing of abuse of discretion. Id. Further, a reviewing

court may not set aside a trial court’s factual findings in the absence of manifest error

or unless it is clearly wrong. Stobart v. State, Through DOTD, 617 So.2d 880

(La.1993); Rosell v. ESCO, 549 So.2d 840 (La.1989). A two-tiered test must be

applied in order to reverse the trial court’s findings: (1) the appellate court must find

from the record that a reasonable factual basis does not exist for the trial court’s

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Related

Stobart v. State Through DOTD
617 So. 2d 880 (Supreme Court of Louisiana, 1993)
Curole v. Curole
828 So. 2d 1094 (Supreme Court of Louisiana, 2002)
Richardson v. Richardson
25 So. 3d 203 (Louisiana Court of Appeal, 2009)
Miller v. Miller
799 So. 2d 753 (Louisiana Court of Appeal, 2001)
Rosell v. Esco
549 So. 2d 840 (Supreme Court of Louisiana, 1989)
Mart v. Hill
505 So. 2d 1120 (Supreme Court of Louisiana, 1987)
Leger v. Leger
854 So. 2d 955 (Louisiana Court of Appeal, 2003)

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Jamie Cass v. Kevin Charlie Cass, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jamie-cass-v-kevin-charlie-cass-lactapp-2010.