Jody LaFlam v. Diana LaFlam

2022 VT 57, 295 A.3d 406
CourtSupreme Court of Vermont
DecidedNovember 4, 2022
Docket21-AP-301
StatusPublished
Cited by1 cases

This text of 2022 VT 57 (Jody LaFlam v. Diana LaFlam) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jody LaFlam v. Diana LaFlam, 2022 VT 57, 295 A.3d 406 (Vt. 2022).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: JUD.Reporter@vermont.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2022 VT 57

No. 21-AP-301

Jody LaFlam Supreme Court

On Appeal from v. Superior Court, Rutland Unit, Family Division

Diana LaFlam September Term, 2022

Helen M. Toor, J.

Jody LaFlam, Pro Se, West Rutland, Plaintiff-Appellee/Cross-Appellant.

Stacey Adamski of Adamski Law, PLLC, Castleton, for Defendant-Appellant/Cross-Appellee.

PRESENT: Reiber, C.J., Eaton, Carroll, Cohen and Waples, JJ.

¶ 1. CARROLL, J. Mother Diana LaFlam appeals from an order denying her motion

to modify physical and legal rights and responsibilities. She argues that her relocation to Florida

following a divorce from father Jody LaFlam was an unanticipated circumstance requiring

modification of the physical rights and responsibilities of their two children, and that father’s

neglect of the children’s health warranted a modification of legal rights and responsibilities. Father

cross-appeals the portion of the order finding that his neglect of the children’s health constituted

changed circumstances under 15 V.S.A. § 668(a). We agree with the family division that mother’s

relocation was not a change in circumstances as to physical rights and responsibilities, that father’s

conduct was a change in circumstances with respect to legal rights and responsibilities, but reverse

and remand as to its best-interests analysis. ¶ 2. The family court found the following by a preponderance of the evidence. Mother

and father divorced in May 2018 after seven years of marriage. Together, mother and father have

a son, aged ten, and a daughter, aged seven. Mother has three daughters from a previous marriage,

one of whom father adopted during the marriage. Adopted daughter was nineteen at the time of

the divorce. The divorce court awarded father sole physical and legal rights and responsibilities

and the family home, and established a fifty-fifty parent-child contact schedule. The divorce order

required father to consult with mother on major decisions regarding son’s and daughter’s “health,

welfare, education or medical needs.”

¶ 3. Father has been inattentive to the children’s medical and hygienic needs since the

divorce. He once forgot to give son the correct asthma inhaler for a sleepover. Father stopped

providing inhalers for son for a period of time without medical approval. Father failed to fill out

a questionnaire required to complete an important evaluation based on a referral from son’s

pediatrician. After son was injured, father did not know if son’s tetanus shot was up to date, which

it was not. Father did not take son to an orthodontist despite a recommendation to do so. He failed

to require the children to consistently attend mental-health counseling after mother moved to

Florida. Father did not require the children to bathe for several days, after which son developed a

bacterial infection. Father ignored a serious rash that daughter had developed related to a

medication she was taking. Daughter developed a different rash for several days and cried when

she went to the bathroom. She told the doctor that there was not enough toilet paper at home to

properly wipe.

¶ 4. The children act differently depending on whether they are in Vermont or Florida.

When in Florida, son, who arrives reserved, becomes more relaxed during the stay. Daughter is

happy and excited to see everyone. Son and daughter are close to adopted daughter and mother’s

new husband in Florida. The children do not want to leave.

2 ¶ 5. When in Vermont, son is stiff and gives one-word answers on video calls with

mother. Daughter also looks sad and whispers, appearing to be checking to see if anyone is

listening to the conversation. Both children have told mother that “what happens at Dad’s house

stays at Dad’s house.” In Vermont, the children spend every other weekend with their

grandparents. During the pandemic, the children completed their online schoolwork from their

grandparents’ home. Both children do well in school. Father gets them to school on time. The

family division credited the testimony of a fellow coach at the children’s school who stated that

daughter is happy, neither son nor daughter showed any fear of father, and father is appropriate

with his children. However, the marital home is in foreclosure proceedings following father’s

failure to pay the mortgage for three years.

¶ 6. In July 2021, shortly before moving to Florida, mother filed a motion seeking to

modify parental rights and responsibilities and parent-child contact. Mother contended that her

move to Florida was a real, substantial, and unanticipated change in circumstances requiring a

modification of the physical custody of the children. Mother argued that father’s inattention to the

children’s health was a real, substantial, and unanticipated change in circumstances sufficient to

modify legal custody of the children. Mother alleged that she had come to realize that father had

been sexually abusive toward her during the marriage. She maintained that she had first realized

this while in therapy in the spring of 2021. In addition, mother attached an affidavit to the motion

in which adopted daughter accused father of sexually inappropriate behavior with her prior to the

divorce. Mother framed these allegations of pre-divorce sexual abuse as appropriate for the court

to consider only under the best-interests factors in 15 V.S.A. § 665, and not as evidence of a real,

substantial, and unanticipated change in circumstances since the divorce.

¶ 7. Following a two-day evidentiary hearing, during which mother, father, and adopted

daughter testified, the family division denied mother’s request to modify parental rights and

responsibilities. The family division concluded that mother’s move to Florida was not

3 unanticipated because the May 2018 final divorce and custody order considered her potential move

to Florida.1 The court however concluded that father’s neglect of the children’s medical needs

was a real, substantial, and unanticipated change regarding legal custody and proceeded to weigh

the statutory best-interests factors in 15 V.S.A. § 665. The court found that mother was better able

to provide medical care, that mother’s housing situation was more stable than father’s, and that

father was not fostering the children’s needs to speak freely without risking punishment or

disapproval. On the other hand, it found that father was better able to serve the children’s

developmental needs, and that mother chose to move to Florida despite knowing she would see

the children less. The court found that there was little evidence regarding the children’s

connections to school and community, which did not favor either parent. It found that neither

parent interfered with the children’s contact with the other parent, which favored neither parent,

and that “no issue [was] raised as to who has been the primary care provider.” The court therefore

gave no weight to the primary-care-provider factor. It found that the children’s relationships with

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2022 VT 57, 295 A.3d 406, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jody-laflam-v-diana-laflam-vt-2022.