Jonathan Patrick v. Morgan Patrick

CourtCourt of Civil Appeals of Alabama
DecidedDecember 19, 2025
DocketCL-2025-0117
StatusPublished

This text of Jonathan Patrick v. Morgan Patrick (Jonathan Patrick v. Morgan Patrick) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jonathan Patrick v. Morgan Patrick, (Ala. Ct. App. 2025).

Opinion

Rel: December 19, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2025-2026 _________________________

CL-2025-0117 _________________________

Jonathan Patrick

v.

Morgan Patrick

Appeal from Madison Circuit Court (DR-23-900081.80)

FRIDY, Judge.

This is the second time Jonathan Patrick ("the husband") and

Morgan Patrick ("the wife") have come before this court in this divorce

action. In Patrick v. Patrick, 419 So. 3d 555, 557 (Ala. Civ. App. 2024),

the husband appealed the judgment of the Madison Circuit Court ("the CL-2025-0117

trial court") divorcing him from the wife, dividing their marital assets,

awarding the wife alimony, and awarding him sole legal and sole physical

custody of the parties' eight-year-old child ("the child"). In that appeal,

we reversed the judgment insofar as it awarded the wife alimony and

divided the parties' marital property and remanded the case with

instructions to the trial court to comply with the requirements of § 30-2-

57, Ala. Code 1975. The trial court has entered an amended judgment, as

directed, without changing the amount of the alimony award or the

division of the marital property. The husband, appearing pro se, appeals

from the amended divorce judgment. For the reasons set forth herein, we

affirm the judgment.

Background

The parties married on June 8, 2013, and the child was born almost

two years later. On January 27, 2023, the husband commenced a divorce

action against the wife, and, on April 5, 2023, the wife answered the

complaint and filed a counterclaim for divorce. The trial court held a trial

in the action on January 30, 2024.

The husband, who was thirty-nine years old at the time of the trial,

testified that the wife and he met on an Internet site and began a long-

2 CL-2025-0117

distance relationship. The wife lived in Ohio and the husband was an

undergraduate student and working at the University of Alabama at

Huntsville ("UAH"). The parties dated for about four years before getting

married, he said. After the wife moved to Alabama in 2009, the husband

said, he realized that she had a drinking problem, which, he said, was a

"frequent point of friction in [their] relationship." The husband did not

drink alcohol and said that he would characterize himself as naіve about

alcohol consumption.

At the trial, the wife's testimony was often confusing or evasive.

She said that she had been in a detoxification center in the weeks leading

up to the January 2024 trial because, as she put it, she had "an alcohol

problem." She said that she had been treated in an alcohol-rehabilitation

center once before but that that treatment had not been successful. In

addition to receiving treatment at rehabilitation facilities, the wife said,

she had been hospitalized several times for alcohol-related issues,

including pancreatitis, in the five years leading up to the husband's filing

of the divorce complaint, and doctors had told her that she would die if

she did not stop drinking. The wife, who was forty years old when the

trial was held, acknowledged that she had been drinking one and a half

3 CL-2025-0117

to two pints of alcohol a day. During the litigation of this case, the trial

court ordered the wife to submit to color-code alcohol testing, but she did

not comply, saying that she did not have the money to do so.

The wife conceded that her alcohol use had had a negative effect on

the marriage. However, she said, the husband had been "an enabler,"

bringing alcohol home to her. She said that she believed that the husband

bought the alcohol about 75% of the time. Even after the husband filed

the divorce action, the wife said, he bought about 40% or 50% of the

alcohol she drank. She said that she asked the husband to attend

counseling so that he would understand living with a recovering addict

but that he did not follow through with that request. She also testified

that the husband's conduct had a role in the breakdown of the marriage.

She said that "he became old too quick" and that there were things she

still wanted to do. She said that, "[o]nce he got his big boy job, he wasn't

coming home as much." When the husband was home, she said, he would

"sit in front of the Xbox," adding that they never went anywhere or did

anything.

The husband testified that he had purchased alcohol for the wife,

but not to the extent to which the wife testified. He explained that the

4 CL-2025-0117

wife was not openly drinking in front of him and was sneaking alcohol

into the house. In 2021, the husband said, he confronted the wife about

her drinking and told her it had to stop. He said that she told him that

the way that he could help her "was by buying it and hiding it in the

house so that she could taper off." He said that he "would pour a shot and

hide it, and then whenever the [wife's] craving got too bad, she would go

find wherever [he] hid it and then drink it." He said that he first

purchased liquor for the wife in 2021. However, the husband said, the

wife then began calling him at work to tell him that she "need[ed] a pint,"

and so, he said, he would buy liquor for her so that she would not drink

and drive. Once the divorce action had been filed, the husband said, he

bought liquor for the wife when she would have some item of his and

threaten to damage it if he did not buy her alcohol.

The wife admitted that, during the marriage, she had had

"inappropriate" relationships with a man in Germany, D.H., and a man

in Finland, J.L., both of whom she met on the Internet. She admitted

"sexting" with both men. She volunteered that she "really liked" D.H. and

"was tapped out of the marriage by then." She testified that she had told

the husband that she was thinking about moving to Germany and that

5 CL-2025-0117

she was thinking about having a child with D.H. She said that the last

time she had talked with him was the day before the trial.

The wife said that J.L came to Huntsville and that she had sex with

him at his hotel. She said that she had told J.L. that she loved him and

that she had talked about having a baby with him as well, adding that

she wanted another child. The last time she had talked to him was the

morning of the trial.

The wife said that, during the pendency of the case, she had sent

money to both D.H. and J.L. to repay loans they had made to her, but, it

was pointed out, during her deposition she had said that she was sending

one of the men money to buy a crock-pot for his mother. She testified that

she was using the husband's money to repay the loans.

The husband testified that he became aware of the wife's

relationship with D.H. in early 2021, when he saw sexually explicit

messages on the wife's cellular telephone. He said that he demanded that

she end the relationship, but the wife continued it. He said that he

learned about J.L.

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Jonathan Patrick v. Morgan Patrick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jonathan-patrick-v-morgan-patrick-alacivapp-2025.