Jamie Patterson v. Martha Allen

CourtCourt of Appeals of Kentucky
DecidedMarch 21, 2024
Docket2022 CA 001248
StatusUnknown

This text of Jamie Patterson v. Martha Allen (Jamie Patterson v. Martha Allen) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jamie Patterson v. Martha Allen, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 22, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1248-MR

JAMIE PATTERSON AND PAUL PENNINGTON APPELLANTS

APPEAL FROM KNOX FAMILY COURT v. HONORABLE STEPHEN M. JONES, JUDGE ACTION NO. 21-CI-00274

MARTHA ALLEN AND BRIAN LEDFORD APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CETRULO, AND TAYLOR, JUDGES.

CETRULO, JUDGE: Married Appellants Jamie Patterson and Paul Pennington

(“Fictive Kin”)1 appeal the judgment of the Knox Family Court vacating their de

facto custodianship status. After careful review, we affirm.

1 “‘Fictive kin’ means an individual who is not related by birth, adoption, or marriage to a child, but who has an emotionally significant relationship with the child[.]” Kentucky Revised Statute 199.011(9). I. BACKGROUND

The twin children involved, L.A. and L.A. (“twins”), were born on

October 17, 2018, in Barbourville, Kentucky. Shortly after their birth, the Cabinet

for Health and Family Services (“Cabinet”)2 became involved with the twins

because they were born substance exposed.3 On August 22, 2019, the Cabinet

placed the twins with Fictive Kin. On October 23, 2019, the Knox Family Court

granted custody to the Cabinet and the Cabinet kept the primary placement with

Fictive Kin. Fictive Kin joined the Foster Program on July 22, 2020, and received

their last payment through that program in May 2021.

On July 1, 2021, Fictive Kin filed a petition for custody requesting the

court designate them de facto custodians of the twins (pursuant to Kentucky

Revised Statute (“KRS”) 403.270 and KRS 403.280) and requesting an emergency

custody order (pursuant to KRS 620.060). At the time of that filing, the twins were

two years old4 and had lived with Fictive Kin for one year, ten months, and six

2 The parties refer to the state entity as the Department for Community Based Services and/or the Cabinet for Health & Family Services. For clarity and consistency, we will refer to the state agency as the “Cabinet.” 3 As a result, the twins’ biological mother, Appellee Martha Allen, lost custody of them shortly after their birth and was subsequently deemed unfit. She did not file a brief in this appeal. 4 At the February 16, 2022 hearing and the June 10, 2022 hearing, the twins’ biological father represented that the twins were three years old at the time Fictive Kin filed for de facto custody. However, that is not accurate. The record reflects the children were born October 17, 2018, and Fictive Kin filed on July 1, 2021, making the twins two years, eight months, and 15 days old on July 1, 2021.

-2- days.5 Of that time, the twins were with Fictive Kin for about ten months as fictive

kin,6 then ten months as foster parents,7 then two months as fictive kin again.8

After filing for de facto custodianship, the twins remained with Fictive Kin for

another six months.9

In December 2020, the Cabinet started the twins’ visitation with

Appellee Brian Ledford (“Biological Father”), but his paternity was not established

until June 24, 2021.10 On September 20, 2021, Biological Father filed a petition

for custody. The Knox Family Court consolidated the action initiated by Fictive

Kin’s petition and the action initiated by Biological Father’s petition.

On October 13, 2021, the Cabinet filed a motion to dismiss Fictive

Kin’s petition. The Cabinet argued Fictive Kin lacked standing to pursue custody

of the twins as they had executed a foster agreement. Fictive Kin asserted they

were no longer enrolled with the Foster Program and had not received assistance

from that program since May or June 2021. On January 14, 2022, the court

5 The actual timeframe was one year, ten months, ten days, but Fictive Kin testified during the February 16, 2022 hearing that the twins were with their biological mother for four of those days. 6 August 22, 2019, to July 2020. 7 July 2020 to May 2021. 8 May 2021 to July 2021. 9 July 1, 2021, to January 14, 2022. 10 After the twins’ birth, and until Ledford established paternity, a different man was presumed to be the father.

-3- transferred custody to Biological Father. In February 2022, the Cabinet was

dismissed as a party.

On February 16, 2022, the Knox Family Court held a de facto hearing,

and on April 6, 2022, the court entered an order (“April 2022 Order”) that found

Fictive Kin proved their status as de facto custodians of the twins. The court found

KRS 403.270 to be controlling.

“[D]e facto custodian” means a person who has been shown by clear and convincing evidence to have been the primary caregiver for, and financial supporter of, a child who within the last two (2) years has resided with the person for an aggregate period of six (6) months or more if the child is under three (3) years of age and for an aggregate period of one (1) year or more if the child is three (3) years of age or older or has been placed by the [Cabinet]. Any period of time after a legal proceeding has been commenced by a parent seeking to regain custody of the child shall not be included in determining whether the child has resided with the person for the required minimum period.

KRS 403.270 (emphasis added).

The April 2022 Order stated that:

The [Fictive Kin] herein are the de facto custodians of the [twins], as they have demonstrated by clear and convincing evidence that they have been the primary caregivers and financial supporters of [the twins], now three (3) years of age, for more than one (1) year, and they have clearly established that the [twins] w[ere] placed with them by [the Cabinet] pursuant to KRS 403.270(1).

-4- Six days after the Knox Family Court entered the April 2022 Order,

Biological Father filed a motion to alter, amend, or vacate that order. Biological

Father argued that the trial court erred because time as foster parents could not be

counted toward the one-year custodial requirement of KRS 403.270. The court

overruled that motion and set a hearing to determine visitation, custody, and/or

parenting time. On June 2, 2022, Biological Father filed a motion to reconsider

and a motion to cancel the hearing.

On June 10, 2022, the Knox Family Court held the hearing. At that

hearing, Biological Father asserted that Fictive Kin had only accrued 273 days of

time with the twins, not the one year required by statute. The court took testimony

from the parties regarding the best interest of the twins.11 At the close of that

hearing, the court did not orally rule on the motion to reconsider but ordered

mediation – within the next 29 days – on the issue of visitation alone.

On July 12, 2022, Fictive Kin sought to compel mediation and on

August 17, 2022, the Knox Family Court entered an order directing Biological

Father to “participate and negotiate in good faith” or “be held in contempt and

sanctioned appropriately.” On September 21, 2022, Fictive Kin filed a motion for

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Bluebook (online)
Jamie Patterson v. Martha Allen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jamie-patterson-v-martha-allen-kyctapp-2024.