Julie Werner Crowe v. Michael James Crowe

CourtCourt of Appeals of Kentucky
DecidedJanuary 5, 2023
Docket2020 CA 001507
StatusUnknown

This text of Julie Werner Crowe v. Michael James Crowe (Julie Werner Crowe v. Michael James Crowe) 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
Julie Werner Crowe v. Michael James Crowe, (Ky. Ct. App. 2023).

Opinion

RENDERED: JANUARY 6, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-1507-MR

JULIE WERNER (FKA JULIE CROWE) APPELLANT

APPEAL FROM DAVIESS FAMILY COURT v. HONORABLE JOHN M. MCCARTY, JUDGE ACTION NO. 17-CI-00039

MICHAEL JAMES CROWE APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, DIXON, AND K. THOMPSON,1 JUDGES.

THOMPSON, K., JUDGE: Julie Werner (FKA Julie Crowe) appeals two orders of

the Daviess Family Court. The first order, entered March 26, 2020, denied her

Kentucky Rules of Civil Procedure (CR) 60.02 motion to set aside the family

court’s decree regarding Werner’s division of marital property with her now ex-

1 Judge Kelly Thompson authored this Opinion before his tenure with the Kentucky Court of Appeals expired on December 31, 2022. Release of this Opinion was delayed by administrative handling. husband, appellee Michael James Crowe. The second order, entered October 23,

2020, denied Werner’s additional motion for a declaration of rights regarding two

Merrill Lynch accounts which were not divided in the decree. We affirm because

it was not unconscionable for the family court to rely on the parties’ waiver of their

rights in agreeing to the property settlement without more judicial oversight,

Werner has not alleged fraud but rather appears to “second-guess” the wisdom of

entering into a property settlement agreement and waiving her additional rights to

judicial oversight, and the parties consented to Merrill Lynch accounts being

awarded to Crowe.

On January 11, 2017, Werner filed a verified petition in family court

to dissolve her marriage with Crowe. Crowe answered shortly afterward, and

nothing more was filed over the course of roughly the next sixteen months. At all

relevant times, both parties were represented by counsel.

On July 11, 2018, Werner and Crowe then filed of record: (1) sworn

answers to one another’s discovery interrogatories; (2) a verified property

settlement agreement (PSA); (3) a joint motion for the entry of a decree dissolving

their marriage and incorporating their PSA; and (4) a joint, verified

acknowledgement and motion for waiver indicating that they “waived exchanging

signed and notarized Verified Disclosure Statements,” “the filing of verified

disclosures with the record,” and “the right to a final hearing and further

-2- proceedings.” Later that month, the family court granted their motions; it also

entered a dissolution decree incorporating their PSA, finding it to be “not

unconscionable.”

Roughly a year later, Werner filed a CR 60.02 motion arguing the

PSA was unconscionable and that the family court erred in failing to so rule. She

sought to have the PSA and the decree incorporating it either set aside or modified.

The family court denied Werner’s motion. Werner now appeals,

arguing: (1) the family court should have set aside the decree pursuant to CR

60.02 because (a) the family court failed to follow its statutory mandate to

determine the conscionability of the PSA; and (b) Crowe’s out of court conduct

amounted to “fraud affecting the proceedings”; or, alternatively, (2) that the family

court had no jurisdiction to effect a post-decree modification of her property

division with Crowe that encompassed two Merrill Lynch accounts that were not

addressed in the PSA.

The reopening of a judgment under Kentucky law is governed by CR

60.02. Relief under CR 60.02 is exceptional and is to be granted cautiously and

available “only under the most unusual and compelling circumstances.” Age v.

Age, 340 S.W.3d 88, 94 (Ky. App. 2011). The decision to grant or to deny a CR

60.02 motion lies within the sound discretion of the family court and we will not

disturb its decision absent an abuse of that discretion. Age, 340 S.W.3d at 94.

-3- Only a decision that is “arbitrary, unreasonable, unfair, or unsupported by sound

legal principles” constitutes an abuse of discretion. Id. (quoting Commonwealth v.

English, 993 S.W.2d 941, 945 (Ky. 1999)).

In relevant part, CR 60.02 sets forth six grounds upon which relief

from a final judgment may be granted. Werner does not connect what she alleges

were procedural errors with any specific ground identified in CR 60.02. In her

appellate brief, she summarizes her argument as follows:

The Trial Court failed to follow its statutory mandate under [Kentucky Revised Statutes] KRS 403.180 to determine the conscionability of the parties’ PSA as it was legally and factually impossible to do so given the failure of the parties to neither exchange and file mandatory preliminary verified disclosure statements nor final verified disclosure statements.

However, Werner’s arguments that the family court “failed to follow

its statutory mandate” and did something “legally and factually impossible”

involved facts that should have been known to her prior to when she asked the

family court to approve her PSA with Crowe and enter its decree. Accordingly,

these are issues she could have raised in a direct appeal; and it is well-established

that CR 60.02 relief is only available for issues that could not be raised in a direct

appeal. McQueen v. Commonwealth, 948 S.W.2d 415 (Ky. 1997). Indeed, Werner

devotes much of her brief to the premise that the family court’s assessment of

“conscionability” was indicative of “clear error,” which is not a ground for relief

-4- under CR 60.02, but rather a standard that would have applied to direct appellate

review of the family court’s decree. See CR 52.01.

To the extent Werner’s argument in this vein could involve any of the

CR 60.02 grounds, it at most appears to implicate subsection (e), which permits a

trial court to vacate a “void” judgment. However, Werner cites no authority – and

we have found none – favoring the proposition that insufficiency of evidence

supporting an unconscionability determination or the failure to file or exchange

verified disclosure statements can render a property division decree void.

Kentucky encourages the amicable resolution of a divorce action by

settlement agreement. KRS 403.250(1) provides that such agreements

incorporated into a decree of dissolution of marriage “may not be revoked or

modified, unless the court finds the existence of conditions that justify the

reopening of a judgment under the laws of this state.”

Pursuant to KRS 403.180, a family court must determine whether a

property settlement agreement “is unconscionable prior to approval of that

agreement.” Peterson v. Peterson, 583 S.W.2d 707, 711 (Ky. App. 1979).

However, making such a determination in the context of an uncontested divorce

proceeding can lead to an issue:

In such cases, the trial court is presented with an agreement which, on its face at least, appears to be reasonable.

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Julie Werner Crowe v. Michael James Crowe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/julie-werner-crowe-v-michael-james-crowe-kyctapp-2023.