Julia Patton v. Gerald Patton

CourtCourt of Appeals of Kentucky
DecidedAugust 17, 2023
Docket2022 CA 000890
StatusUnknown

This text of Julia Patton v. Gerald Patton (Julia Patton v. Gerald Patton) 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
Julia Patton v. Gerald Patton, (Ky. Ct. App. 2023).

Opinion

RENDERED: AUGUST 18, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0890-MR

JULIA PATTON APPELLANT

APPEAL FROM GREENUP CIRCUIT COURT v. HONORABLE JEFFREY L. PRESTON, JUDGE ACTION NO. 21-CI-00282

GERALD PATTON APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, COMBS, AND LAMBERT, JUDGES.

LAMBERT, JUDGE: Julia Patton appeals from the Greenup Circuit Court’s

orders pertaining to the dissolution action filed by her former husband, Gerald

Patton. She also requests that this Court reverse and remand the maintenance

award regarding its duration. We affirm.

The parties were married in late 1991 and separated thirty years later.

The Pattons had no children. Gerald is self-employed at Independent Contractors

Distributors, Inc. (ICD), a company originally owned by Gerald’s father but gifted to Gerald in 2003. Julia received paychecks from ICD although she rarely worked

there. The annual salary from ICD for each spouse was $106,000.00. The parties

also own Last Chance Farm, comprised of over 300 acres. They additionally own

several rental properties. The farm and rental homes are mortgaged. After

separation, Julia continued to live on and operate the farm (where the marital home

is situated), while Gerald lived elsewhere.

An agreed order was entered in October 2021. Among other

provisions, Julia was to receive temporary maintenance of $2,000.00 per week.

She was also supposed to collect rent, pay for the upkeep on the farm, and make

the mortgage payments on the rental properties once rents were collected. Gerald

continued to pay the mortgage, utilities, and normal operating expenses for the

house and farm. Julia was given a credit card as well as occasional blank checks

with which to keep up with expenses. Her health insurance and out of pocket

medical costs were to be paid by Gerald. Both parties agreed not to dissipate

marital assets.

The final hearing was held on April 26, 2022. Both parties testified as

did an accountant for ICD. The circuit court entered its findings of fact,

conclusions of law, and decree of dissolution two months later. Julia appeals.1

1 The record indicates the parties have continued to file various motions against each other in the circuit court. Our Opinion only addresses the issues presented before this Court.

-2- Julia first argues that the circuit court erred in the duration of

maintenance awarded to her. She specifically insists that $106,000.00 for one year

is insufficient to meet her reasonable needs, citing the factors enunciated in

Kentucky Revised Statute (KRS) 403.200(2)(a) through (f).2 Julia specifies these

factors as supporting her claim that she is unable to meet her reasonable needs: the

length of the marriage (30 years) versus the one-year award of maintenance; the

high standard of living enjoyed by the parties; Julia’s lack of sufficient financial

resources; her age and physical limitations; and Gerald’s superior ability to earn

2 KRS 403.200(2) states:

The maintenance order shall be in such amounts and for such periods of time as the court deems just, and after considering all relevant factors including:

(a) The financial resources of the party seeking maintenance, including marital property apportioned to him, and his ability to meet his needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian;

(b) The time necessary to acquire sufficient education or training to enable the party seeking maintenance to find appropriate employment;

(c) The standard of living established during the marriage;

(d) The duration of the marriage;

(e) The age, and the physical and emotional condition of the spouse seeking maintenance; and

(f) The ability of the spouse from whom maintenance is sought to meet his needs while meeting those of the spouse seeking maintenance.

-3- income. In other words, Julia insists that she meets all the statutory factors for

receiving maintenance, and she requests that the duration of maintenance be

extended until she reaches full social security age. She was 52 years old at the

time of dissolution.

“The statutory test for granting maintenance is whether the spouse is

unable to support her own reasonable needs through her property, including her

part of the marital estate, and is also unable to support herself through suitable

employment.” Normandin v. Normandin, 634 S.W.3d 589, 602 (Ky. 2020), as

modified (Apr. 29, 2021) (citing KRS 403.200(1)). An award of maintenance, and

the amount and duration thereof, is within the circuit court’s sound discretion and

will only be disturbed on appeal if the appellate court “finds the trial court abused

its discretion or based its decision on findings of fact that are clearly erroneous.”

Powell v. Powell, 107 S.W.3d 222, 224 (Ky. 2003), as amended (Aug. 8, 2003);

Brenzel v. Brenzel, 244 S.W.3d 121, 126 (Ky. App. 2008). The test for abuse of

discretion is whether the decision of the circuit court was “arbitrary, unreasonable,

unfair, or unsupported by sound legal principles.” Downing v. Downing, 45

S.W.3d 449, 454 (Ky. App. 2001). This Court is “not authorized to substitute its

own judgment for that of the trial court on the weight of the evidence where the

trial court’s decision is supported by substantial evidence.” Maclean v. Middleton,

419 S.W.3d 755, 775 (Ky. App. 2014). Simply put, the appellate court should

-4- avoid “usurp[ing] the discretion which properly rests in the trial court.” Perrine v.

Christine, 833 S.W.2d 825, 827 (Ky. 1992).

Gripshover v. Gripshover, states: “KRS 403.200 seeks to enable the

unemployable spouse to acquire the skills necessary to support himself or herself

in the current workforce so that he or she does not rely upon the maintenance of

the working spouse indefinitely.” 246 S.W.3d 460, 469 (Ky. 2008) (quoting

Powell, 107 S.W.3d at 224). However, it further held:

We have recognized, however, that the statutory goal of rehabilitation will not always be attainable:

[I]n situations where the marriage was long term, the dependent spouse is near retirement age, the discrepancy in incomes is great, or the prospects for self-sufficiency appear dismal, our courts have declined to follow that policy [rehabilitation] and have instead awarded maintenance for a longer period or in greater amounts. Id. at 470 (quoting Powell, 107 S.W.3d at 224).

Here, Julia does not contest the amount of maintenance, only its

duration of one year post-decree. But while she maintains that she lacks the

education, skills, and physical stamina required to support herself sufficiently, the

record speaks otherwise. Julia continues to work the farm and its many demanding

obligations.

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Related

Gripshover v. Gripshover
246 S.W.3d 460 (Kentucky Supreme Court, 2008)
Downing v. Downing
45 S.W.3d 449 (Court of Appeals of Kentucky, 2001)
Powell v. Powell
107 S.W.3d 222 (Kentucky Supreme Court, 2003)
Neidlinger v. Neidlinger
52 S.W.3d 513 (Kentucky Supreme Court, 2001)
Brenzel v. Brenzel
244 S.W.3d 121 (Court of Appeals of Kentucky, 2008)
Perrine v. Christine
833 S.W.2d 825 (Kentucky Supreme Court, 1992)
Muir v. Muir
406 S.W.3d 31 (Court of Appeals of Kentucky, 2013)
Maclean v. Middleton
419 S.W.3d 755 (Court of Appeals of Kentucky, 2014)
Ensor v. Ensor
431 S.W.3d 462 (Court of Appeals of Kentucky, 2013)
Smith v. McGill
556 S.W.3d 552 (Missouri Court of Appeals, 2018)

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Bluebook (online)
Julia Patton v. Gerald Patton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/julia-patton-v-gerald-patton-kyctapp-2023.