John Anderle v. Michelle Anderle

CourtCourt of Appeals of Kentucky
DecidedJuly 22, 2021
Docket2020 CA 001047
StatusUnknown

This text of John Anderle v. Michelle Anderle (John Anderle v. Michelle Anderle) 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
John Anderle v. Michelle Anderle, (Ky. Ct. App. 2021).

Opinion

RENDERED: JULY 23, 2021; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-1047-MR

JOHN ANDERLE APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE JOAN L. BYER, JUDGE ACTION NO. 10-CI-500157

MICHELLE ANDERLE; MELANIE STRAW-BOONE; AND MICHELE MCKINNEY APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, JONES, AND McNEILL, JUDGES.

COMBS, JUDGE: John Anderle appeals from an order of the Jefferson Family

Court entered on July 30, 2020. In its order, the family court: modified Anderle’s

child support obligation; ordered him to pay to his former spouse, Michelle

Anderle, $4,690.20 as compensation for the loss caused by his failure to abide by an earlier order; and granted Michelle’s motion for attorneys’ fees. After carefully

considering the arguments on appeal, we affirm.

The Anderles divorced on June 30, 2010. In December 2016, John

was laid off from work and began drawing unemployment benefits. Pursuant to

the family court’s order of April 6, 2017, John’s child support obligation for the

only minor child remaining at home was reduced from $1,297 per month to

$309.15 per month. In light of the dramatic reduction in John’s child support

obligation, the family court ordered John to notify Michelle and the court within

three (3) days of his re-employment.

On May 22, 2018, John notified his counsel by email that he would

begin a new job on July 1. He indicated that his salary for 2018 would total

$40,000.00 and asked counsel to calculate “what my child support will be through

the end of the [] year.”

John’s counsel sent an email to Michelle’s counsel on July 2, 2018,

indicating that John had begun a new job the day before. John’s counsel wrote: “I

believe he will be making $45k per year.” Counsel explained that she would

provide proof of John’s income when she received it and expressed her preference

that the couple submit to an agreed order “which includes exchanging income

information by April 15th of each year.”

-2- On June 4, 2019, Michelle filed a motion to modify child support. In

addition, she asked the court to hold John in contempt for his failure to notify the

court of his re-employment under the specific terms of its order of May 1, 2017,

asking also to order him to pay her attorneys’ fees. A hearing was scheduled for

December 12, 2019, at 9:00 a.m., but John and his counsel failed to appear for the

hearing. Later, John’s counsel explained to the court that she was laboring under

the mistaken belief that the hearing was scheduled for 9:30 a.m.

Following its review of the testimony and evidence introduced by

Michelle, the family court modified John’s child support obligation; found that

John had willfully violated its order of May 1, 2017; and ordered John to pay

Michelle’s attorneys’ fees in the amount of $2,770.00.

John filed a motion for a new hearing. The family court conducted

another evidentiary hearing on June 18, 2020, at which Michelle testified that John

had not timely notified her of his re-employment. She indicated that when John

eventually told her he had been re-employed, he assured her that he was working

with his counsel to calculate a new child support obligation and that he would pay

the increased support as of his date of hire. After months of trying to resolve what

she believed would be a straightforward issue, and in the face of John’s growing

belligerence, Michelle testified that she realized she would have to file a motion

with the court for relief.

-3- John testified that he was aware of the court order requiring him to

promptly notify the court of his re-employment in anticipation of a re-calculation

of his child support obligation. He admitted that he had failed to do so. John did

not testify or provide evidence to indicate when he advised Michelle of his re-

employment. However, he denied that he had agreed with Michelle that his child

support obligation as re-calculated would apply as of the date of his re-

employment. He testified with respect to the email that he sent his counsel in May

2018 informing her that he had been re-employed and indicated that the email had

been forwarded to Michelle’s counsel. Michelle’s counsel informed the court that

the firm had not received a forwarded email from John in May 2019. Michelle

filed a post-hearing memorandum and her counsel’s affidavit indicating that

attorneys’ fees from December 13, 2019, through the hearing conducted on June

18, 2020, totalled $4,715.00.

Following its review of the testimony and evidence introduced by

each party, the family court confirmed its modification of John’s child support

obligation, increasing it to $700 per month; confirmed that John had willfully

violated its order of May 1, 2017; and ordered John to pay Michelle’s attorneys’

fees now totalling $7,485.00. As a sanction for his contempt of court, the family

court ordered John to pay $4,690.20 -- the amount of additional support he would

-4- have paid had he complied with the court’s order of May 7, 2017. This appeal

followed.

On appeal, John argues that the court abused its discretion by ordering

him to pay both sanctions for contempt and Michelle’s attorneys’ fees. However,

John does not contest that portion of the court’s order modifying his child support

obligation.

A trial court has broad authority to enforce its orders, and contempt

proceedings are part of that authority. Lewis v. Lewis, 875 S.W.2d 862 (Ky. 1993).

Moreover, KRS1 403.240 provides that a party’s noncompliance with a support or

custody decree “shall constitute contempt of court” and shall be addressed as such.

We review a trial court’s exercise of its contempt powers for abuse of

discretion. Kentucky River Community Care, Inc. v. Stallard, 294 S.W.3d 29 (Ky.

App. 2008). The court abuses its discretion only where its decision is arbitrary,

unreasonable, unfair, or unsupported by sound legal principles. Goodyear Tire and

Rubber Co. v. Thompson, 11 S.W.3d 575 (Ky. 2000). The trial court’s underlying

findings of fact are reviewed for clear error. Commonwealth, Cabinet for Health

and Family Servs. v. Ivy, 353 S.W.3d 324 (Ky. 2011).

Contempt sanctions are classified as either criminal or civil depending

upon whether they are meant to punish the contemnor’s noncompliance with the

1 Kentucky Revised Statutes.

-5- court’s order and to vindicate the court’s authority and dignity (criminal) or

whether they are meant to benefit an adverse party either by coercing compliance

with the order or by compensating for losses the noncompliance occasioned (civil).

Gormley v. Judicial Conduct Commission, 332 S.W.3d 717 (Ky. 2010). Since this

proceeding was meant to compensate for the loss of child support resulting from

John’s failure to comply with the court’s order, it was civil in nature.

In a civil contempt proceeding, the initial burden is on the party

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Related

Kentucky River Community Care, Inc. v. Stallard
294 S.W.3d 29 (Court of Appeals of Kentucky, 2008)
Goodyear Tire and Rubber Co. v. Thompson
11 S.W.3d 575 (Kentucky Supreme Court, 2000)
Gormley v. Judicial Conduct Commission
332 S.W.3d 717 (Kentucky Supreme Court, 2011)
Lewis v. Lewis
875 S.W.2d 862 (Kentucky Supreme Court, 1993)
Dalton v. Dalton
367 S.W.2d 840 (Court of Appeals of Kentucky (pre-1976), 1963)
Gentry v. Gentry
798 S.W.2d 928 (Kentucky Supreme Court, 1990)
Commonwealth, Cabinet for Health & Family Services v. Ivy
353 S.W.3d 324 (Kentucky Supreme Court, 2011)
Roper v. Roper
47 S.W.2d 517 (Court of Appeals of Kentucky (pre-1976), 1932)
Clay v. Winn
434 S.W.2d 650 (Court of Appeals of Kentucky, 1968)
Rumpel v. Rumpel
438 S.W.3d 354 (Kentucky Supreme Court, 2014)
Seeger v. Lanham
542 S.W.3d 286 (Missouri Court of Appeals, 2018)

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John Anderle v. Michelle Anderle, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-anderle-v-michelle-anderle-kyctapp-2021.