John Thrasher v. Jeremy Criswell

CourtCourt of Appeals of Kentucky
DecidedJune 13, 2024
Docket2023 CA 000564
StatusUnknown

This text of John Thrasher v. Jeremy Criswell (John Thrasher v. Jeremy Criswell) 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 Thrasher v. Jeremy Criswell, (Ky. Ct. App. 2024).

Opinion

RENDERED: JUNE 14, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2023-CA-0564-MR

JOHN THRASHER APPELLANT

APPEAL FROM WAYNE FAMILY COURT v. HONORABLE JENNIFER UPCHURCH EDWARDS, JUDGE ACTION NO. 22-CI-00097

JEREMY CRISWELL, JEANNIE CRISWELL AND JADE THRASHER APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ECKERLE, KAREM, AND LAMBERT, JUDGES.

KAREM, JUDGE: John Thrasher appeals from the Wayne Family Court’s

findings of fact, conclusions of law, and order finding him unfit for custody of his

minor child and awarding custody to the child’s maternal grandfather and step-

grandmother. Upon careful review, we affirm. FACTUAL AND PROCEDURAL BACKGROUND

John Thrasher and Jade Thrasher are the biological parents of E.T.,1

who was born in October of 2021. John and Jade got married on October 27, 2021,

and initially resided with John’s parents, Jimmy and Marie Thrasher. In December

2021, they moved in with Jade’s father and stepmother, Jeremy and Jeannie

Criswell. John and Jade had marital problems and at the end of March or early

April 2022, John moved out of the Criswells’ home.

Three separate actions involving E.T. then commenced: a

dependency, neglect, and abuse (DNA) action brought by the Wayne County

Attorney on behalf of the Criswells; a dissolution of marriage action brought by

John; and a custody action brought by the Criswells.

The DNA action was initiated on April 12, 2021, when the Wayne

County Attorney filed an emergency petition on behalf of the Criswells, alleging

neglect of E.T. by John and Jade and seeking her temporary removal. The family

court entered an order granting temporary custody to the Criswells and timesharing

for John and Jade.

On April 18, 2022, John filed a petition for dissolution of his marriage

to Jade and for custody of E.T.

1 Kentucky Rules of Appellate Procedure (RAP) 5(B)(2), requires the use of initials instead of a name in cases involving juveniles, allegations of abuse and neglect, termination of parental rights, mental health, and expungements.

-2- On May 3, 2022, the Criswells filed a petition for third-party custody

of E.T., contending they were de facto custodians or, in the alternative, that John

and Jade were unfit parents.

On August 23, 2022, the family court entered an order dismissing the

petition in the DNA action and leaving in place the existing custody arrangement,

with the Criswells as temporary custodians and the parents exercising temporary

timesharing, pending the final hearing in the Criswells’ custody action.

On September 14, 2022, the family court entered an order dissolving

John and Jade’s marriage. Issues relating to E.T.’s custody were bifurcated from

the dissolution action.

On October 30, 2022, before the final hearing on custody, John was

involved in a one-vehicle accident. According to the arrest citation, his truck was

found upside-down beside the highway. It was alleged that his passenger, who was

thirteen years of age, had consumed alcohol provided to him by John. John failed

a field sobriety test, and the results of his blood test were still pending at the time

of the final hearing. He was charged with first-degree driving under the influence

(DUI), unlawful transaction with a minor in the third degree, and wanton

endangerment in the second degree. Upon motion by the Criswells, the court

ordered John’s visitation with E.T. to be supervised by his parents.

-3- The final hearing on custody was conducted on November 21, 2022.

Jade filed an entry of appearance in the action and expressed her consent to the

Criswells’ petition for custody.

The family court thereafter entered its findings of fact, conclusions of

law, and order. It determined that the Criswells did not qualify as de facto

custodians. On the date John filed his petition for custody in the underlying DNA

action, E.T. was not yet six months of age and therefore the Criswells could not

meet the six-month period necessary to qualify as de facto custodians under

Kentucky Revised Statutes (KRS) 403.270.

The court did conclude, however, that the Criswells had shown by

clear and convincing evidence that John was an unfit parent. It found that John

and Jade’s behavior created a substantial risk of physical injury to E.T., due to

John’s alcohol abuse and his provision of alcohol to minors; John and Jade’s

physical violence against each other and family members; and John’s untreated

mental health issues and threats of self-harm. The court also found that Jade and

John failed to provide essential care for E.T. In regard to John, this finding was

based on evidence of his reluctance to work and his failure to use any income he

did earn to support E.T.; his failure to provide housing for E.T.; and his failure to

take an active role in parenting E.T.

-4- The family court granted sole custody of E.T. to the Criswells. Jade

was granted visitation to be supervised by the Criswells. John was granted

visitation every other weekend to be supervised by Jimmy or Marie Thrasher until

he completed substance abuse and mental health assessments and tendered written

proof to the Court that he has completed the recommendations resulting from those

assessments. Upon tendering this proof, his visitation would be unsupervised.

John was also granted holiday visits with E.T. on Thanksgiving, Christmas Day,

Easter Sunday, E.T.’s birthday, and Father’s Day.

This appeal by John followed.

STANDARD OF REVIEW AND LEGAL FRAMEWORK

In reviewing a child-custody award, the appellate standard of review includes a determination of whether the factual findings of the family court are clearly erroneous. A finding of fact is clearly erroneous if it is not supported by substantial evidence, which is evidence sufficient to induce conviction in the mind of a reasonable person. Since the family court is in the best position to evaluate the testimony and to weigh the evidence, an appellate court should not substitute its own opinion for that of the family court. If the findings of fact are supported by substantial evidence and if the correct law is applied, a family court’s ultimate decision regarding custody will not be disturbed, absent an abuse of discretion. Abuse of discretion implies that the family court’s decision is unreasonable or unfair. Thus, in reviewing the decision of the family court, the test is not whether the appellate court would have decided it differently, but whether the findings of the family court are clearly erroneous, whether it applied the correct law, or whether it abused its discretion.

-5- B.C. v. B.T., 182 S.W.3d 213, 219-20 (Ky. App. 2005) (footnotes and citations

omitted).

“Parents of a child have a fundamental, basic, and constitutional right

to raise, care for, and control their own children.” Mullins v. Picklesimer, 317

S.W.3d 569, 578 (Ky. 2010), as modified on denial of reh’g (Aug. 26, 2010).

When, as in this case, non-parents do not meet the statutory definition of de facto

custodians under KRS 403.270, they “must prove either of the following two

exceptions to a parent’s superior right or entitlement to custody: (1) that the parent

is shown by clear and convincing evidence to be an unfit custodian, or (2) that the

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John Thrasher v. Jeremy Criswell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-thrasher-v-jeremy-criswell-kyctapp-2024.