Joyce M. Tymczyszyn (fka Joyce A. Mcmahon), V. Joseph P. Tymczyszyn

CourtCourt of Appeals of Washington
DecidedJanuary 12, 2026
Docket87324-5
StatusUnpublished

This text of Joyce M. Tymczyszyn (fka Joyce A. Mcmahon), V. Joseph P. Tymczyszyn (Joyce M. Tymczyszyn (fka Joyce A. Mcmahon), V. Joseph P. Tymczyszyn) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joyce M. Tymczyszyn (fka Joyce A. Mcmahon), V. Joseph P. Tymczyszyn, (Wash. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

JOYCE MCMAHON TYMCZYSZYN, No. 87324-5-I Appellant, DIVISION ONE v. UNPUBLISHED OPINION JOSEPH PAUL TYMCZYSZYN,

Respondent.

HAZELRIGG, C.J. — Joyce McMahon Tymczyszyn appeals the denial of her

motion to vacate the final order that dissolved her marriage in 1989 based on her

allegations of fraud. Because the trial court did not err when it denied her motion,

we affirm.

FACTS

Joyce and Joseph Tymczysyn 1 were married in 1976. The couple filed for

dissolution of the marriage, which Joyce signed as the petitioner and Joseph

expressly joined, in April 1989. The trial court entered final orders on the

dissolution on July 27, 1989. Over 30 years later, in September 2021, Joyce filed

a motion to vacate the order on dissolution pursuant to CR 60. Joyce’s motion

was premised on allegations of fraud under CR 60(b)(4) and a general request for

relief pursuant to CR 60(c). Joyce supported her motion with a declaration and

1 Because the parties share the same last name, we use their first names for clarity. No disrespect is intended. No. 87324-5-I/2

later filed a supplemental declaration, as well as a motion for an in-person hearing

and authorization to serve Joseph via certified mail. Joseph did not file a response.

On November 4, 2021, the trial judge entered an order denying Joyce’s

motion to vacate that stated, “Much of the petitioner’s declaration appears to be

delusional in nature and, even if believed, does not coherently articulate how the

alleged fraud or misconduct relates to the divorce action.” The order also noted

that the relief requested, “to be ‘restored to her status as wife as if there had never

been a decree of dissolution’ including ordering the parties into joint counseling for

Stockholm syndrome, is not relief that would be ordered by this court.” Further,

the trial court explained that CR 60 motions to vacate must be brought within a

reasonable time and, although Joyce claimed to have discovered the purported

fraud within the three years preceding her motion, “most evidence she presents

dates from the time of the divorce.” The trial judge also ordered the sealing of

mental health records that Joyce had filed to accompany her declaration.

Joyce renewed her efforts several years later. On September 13, 2024, she

filed another motion to vacate and a substantially similar supporting declaration.

However, the 2024 motion omitted any mention of CR 60 and instead simply

identified “fraud” as the issue for the court to decide. 2 The same day, and without

a hearing, the trial court denied her motion again and stated that “having reviewed

a motion for order to vacate a decree of dissolution[, the court] denies motion for

2 Despite not designating this motion as one under CR 60, the trial court substantively

treated it as such based on the relief sought.

-2- No. 87324-5-I/3

the same reasons stated in the [c]ourt’s order denying a virtually identical motion

in 2021 and based on the doctrines of claim and issue preclusion.”3

Joyce timely appealed.

ANALYSIS

Only the September 13 order denying Joyce’s 2024 motion to vacate is

before us in this appeal. However, the 2024 order expressly incorporated the

reasoning of the 2021 order denying her CR 60 motion and added issue and claim

preclusion as additional bases for denying the 2024 motion. Because the 2024

order relies on the justifications from the 2021 order, we consider the 2021 order

only to the extent that its reasoning was incorporated by reference into the 2024

order.

I. Motion To Vacate

While Joyce’s 2024 motion did not explicitly invoke CR 60, the trial court

treated it as a motion under that rule, likely because of its marked similarity to the

motion Joyce filed in 2021 that sought the same relief but with express reliance on

CR 60. Our State Supreme Court has long held that the substance of a pleading

should determine how it is considered. See Pamelin Indus., Inc. v. Sheen–U.S.A.,

Inc., 95 Wn.2d 398, 401-02, 622 P.2d 1270 (1981) (holding intent and purpose of

motion can properly be inferred from its substance). In light of the fact that Joyce’s

nearly identical 2021 motion rested entirely on CR 60 and the contention put forth

in both motions was that vacatur was necessary due to fraud, the court properly

3 Understandably, as the motion was decided the same day it was filed, Joseph did not file

a response to the 2024 motion to vacate.

-3- No. 87324-5-I/4

assessed the merits of her 2024 motion to vacate as rooted in CR 60. However,

her briefing on appeal fails to meaningfully engage with CR 60 and case law

interpreting the rule, but instead reiterates the substance of her claims, attempts

to apply case law related to civil claims of fraud, and asserts that the trial court

erred by failing to vacate the decades old dissolution order. In response, Joseph

contends that the “trial court correctly denied Ms. Tymczyszyn’s motion to vacate

initially in 2021, as the motion was without merit, and was untimely. The court

again properly denied the motion in 2024, for the same reasons, in addition to the

fact that the motion was barred to to [sic] issue preclusion.”

We, like the trial court, consider this case under the framework of CR 60.

CR 60(b) authorizes the trial court to “relieve a party or the party’s legal

representative from a final judgment, order, or proceeding.” The rule provides

specific grounds for relief from fraud, which can be “intrinsic or extrinsic,” that

results from a misrepresentation or “other misconduct of an adverse party.” CR

60(b)(4). Notably, the rule requires that such a motion “be made within a

reasonable time.” CR 60(b). “Courts have observed that what constitutes a

reasonable time depends on the facts of the case.” In re Marriage of Thurston, 92

Wn. App. 494, 500, 963 P.2d 947 (1998). When we consider the timeliness of a

CR 60 motion, we look for prejudice to the nonmoving party and whether the

moving party had a “a good reason for failing to take action sooner.” Id.

We review the trial court’s denial of a CR 60 motion for an abuse of

discretion. In re Marriage of Bresnahan, 21 Wn. App. 2d 385, 406, 505 P.3d 1218

(2022). The trial court abuses its discretion if it “‘bases its ruling on an erroneous

-4- No. 87324-5-I/5

view of the law.’” Id. (internal quotation marks omitted) (quoting In re Marriage of

Selley, 189 Wn. App. 957, 959, 359 P.3d 891 (2015)). The trial court also abuses

its discretion if the “decision is ‘outside the range of acceptable choices, given the

facts and the applicable legal standard.’” Id. (quoting In re Marriage of Littlefield,

133 Wn.2d 39, 47, 940 P.2d 1362 (1997)). Our Supreme Court has instructed that

“CR 60 is a limited procedural tool that governs relief from final judgments,” the

“rule balances the principles of equity and finality,” and courts cannot grant

affirmative relief pursuant to the rule. Fireside Bank v. Askins, 195 Wn.2d 365,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Marriage of Littlefield
940 P.2d 1362 (Washington Supreme Court, 1997)
Pamelin Industries, Inc. v. Sheen-U.S.A., Inc.
622 P.2d 1270 (Washington Supreme Court, 1981)
In Re the Marriage of Thurston
963 P.2d 947 (Court of Appeals of Washington, 1998)
Cynthia L. Selley v. Jason S. Selley
359 P.3d 891 (Court of Appeals of Washington, 2015)
Fireside Bank v. Askins
460 P.3d 157 (Washington Supreme Court, 2020)
In re the Marriage of Littlefield
133 Wash. 2d 39 (Washington Supreme Court, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Joyce M. Tymczyszyn (fka Joyce A. Mcmahon), V. Joseph P. Tymczyszyn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joyce-m-tymczyszyn-fka-joyce-a-mcmahon-v-joseph-p-tymczyszyn-washctapp-2026.