Karen Cohen Kinnett Versus Jarred Brandon Kinnett

CourtLouisiana Court of Appeal
DecidedJuly 7, 2022
Docket17-CA-625
StatusUnknown

This text of Karen Cohen Kinnett Versus Jarred Brandon Kinnett (Karen Cohen Kinnett Versus Jarred Brandon Kinnett) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Karen Cohen Kinnett Versus Jarred Brandon Kinnett, (La. Ct. App. 2022).

Opinion

KAREN COHEN KINNETT NO. 17-CA-625

VERSUS FIFTH CIRCUIT

JARRED BRANDON KINNETT COURT OF APPEAL

STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 768-195, DIVISION "E" HONORABLE WILLIAM H. CREDO, JUDGE PRO TEMPORE PRESIDING

July 07, 2022

FREDERICKA HOMBERG WICKER JUDGE

Panel composed of Judges Fredericka Homberg Wicker, Jude G. Gravois, and Robert A. Chaisson

JUDGMENT ON MOTION IN LIMINE REVERSED; JUDGMENT ON CONSTITUTIONALITY VACATED; REMANDED FOR NEW TRIAL FHW JGG RAC COUNSEL FOR PLAINTIFF/APPELLEE, KAREN COHEN KINNETT Allison K. Nestor Leonard L. Levenson

COUNSEL FOR DEFENDANT/APPELLEE, JARRED BRANDON KINNETT Jacqueline F. Maloney Tracy G. Sheppard

COUNSEL FOR INTERVENOR/APPELLANT, KEITH EDWARD ANDREWS Thomas A. Robichaux Stephanie A. Fratello Sharon L. Andrews Desiree M. Valenti

COUNSEL FOR MINOR/APPELLEE, G. J. K., MINOR CHILD Ramona G. Fernandez and Tobie L. Tranchina, Supervising Attorneys Loyola University New Orleans, College of Law Victoria Barczyk, Student Practitioner Sarah Skidmore, Student Practitioner Olivia Holm, Student Practitioner Cynthia Traina, Student Practitioner

COUNSEL FOR AMICUS CURIAE, STATE OF LOUISIANA, DEPARTMENT OF JUSTICE Honorable Jeffrey M. Landry David J. Smith, Jr. Jeffrey M. Wale Chimene St. Amant WICKER, J.

This matter is before this Court on remand from the Louisiana Supreme

Court to consider biological father appellant, Keith Andrews’, challenge to the

constitutionality of La. C.C. art. 198, an issue which this Court did not consider on

appeal. Kinnett v. Kinnett, 20-01134 (La. 10/10/21), 332 So.3d 1149, 1157.

Upon review of the rulings appealed in connection with Mr. Andrews’

challenge to the constitutionality of La. C.C. art. 198, we find that the trial court

abused its discretion in granting a pre-trial motion in limine and in excluding “any

fact witness” from the trial on Mr. Andrews’ first supplemental petition

challenging the constitutionality of La. C.C. art. 198. We find that the trial court’s

ruling impeded the discovery process and prevented Mr. Andrews from properly

challenging the statute’s constitutionality at trial. We therefore reverse the trial

court’s October 23, 2018 judgment granting the motion in limine, which affected

the presentation of evidence, or lack thereof, permitted at trial, vacate the

subsequent January 10, 2019 judgment holding La. C.C. art. 198 constitutional,

and remand this matter to the trial court to allow the parties to conduct proper

discovery and order the trial court to hold a new trial on Mr. Andrews’

supplemental petition, with factual and/or expert testimony and evidence, raising

the issue of La. C.C. art. 198’s constitutionality.

Procedural History:

The preliminary procedural history is set forth in this Court’s opinion in the

first appeal in this case:

Ms. Kinnett commenced the instant litigation by filing for divorce on January 14, 2017. She sought joint custody with Mr. Kinnett of their daughter, B.A.K., but sole custody of her son, G.J.K. On January 27, 2017, Mr. Kinnett filed his Answer and Reconventional Demand disputing Ms. Kinnett's contention that awarding her sole custody of G.J.K. would be in the child's best interest, urging instead that joint custody be granted.

17-CA-625 1 On February 10, 2017, Mr. Andrews filed a Petition in Intervention to Establish Paternity and to Obtain Custody of G.J.K. In his petition, Mr. Andrews alleged that Ms. Kinnett had concealed his possible paternity until December 9, 2016, and sought an order establishing paternity and an action to obtain custody.

On February 21, 2017, Mr. Kinnett answered Mr. Andrews’ intervention with Exceptions of No Cause and/or No Right of Action, Prescription, and Peremption, arguing that Mr. Andrews’ avowal action was perempted under Louisiana Civil Code art. 198 because he failed to file an action within one year of G.J.K.’s birth. On February 24, 2017, the court appointed the Loyola Law Clinic to represent the interests of the minor child. Ms. Kinnett first filed a memorandum opposing the exceptions on April 10, 2017, however, on May 31, 2017, she filed a second memorandum supporting the exceptions. On appeal, Ms. Kinnett adopted the arguments in Mr. Kinnett’s appellee briefs.

At the initial April 12, 2017 hearing, the Domestic Commissioner denied the exceptions of no right of action and no cause of action as to paternity, and granted the exception of no cause of action as to custody. He also granted the exception of peremption, finding that Mr. Andrews should have known G.J.K. was his child given that he had “intimate contact” with Ms. Kinnett nine months prior to the child’s birth. Mr. Andrews objected to the Commissioner’s ruling, contending in pertinent part that the “time limitations in Civil Code article 198 are constitutionally invalid.”

The parties tried the exceptions de novo before the district court on June 2, 2017. The district court judge ruled from the bench denying the exceptions of no cause of action and no right of action as to paternity, but granting the exceptions of no cause of action and no right of action as to custody and visitation. The judge further held that Mr. Andrews’ avowal action was perempted under Article 198 based on his finding that (a) Mr. Andrews had not proven “that the mother was actually in bad faith and intended to deceive,” and (b) he had filed his avowal action more than a year from the time the judge determined he knew or should have known that he was G.J.K.’s father. The trial court declined to rule on the constitutionality of the statute and denied Mr. Andrews’ motion for additional time to notify the attorney general and further plead the constitutionality issue. Mr. Andrews appealed the June 2, 2017 judgment to this Court.

On March 23, 2018, this Court stayed this appeal and remanded the case to the trial court to allow Mr. Andrews the opportunity to amend his petition and appropriately challenge the constitutionality of Article 198. Kinnett v. Kinnett, 17-CA-625, per curiam, p. 4. On April 6, 2018, Mr. Andrews filed his First Supplemental and Amending Petition, formally challenging Article 198’s constitutionality, thereafter notifying the Louisiana Attorney General as required by law. The Law Clinic filed a memorandum in support of Mr. Andrews’ Supplemental and Amending Petition on June 4, 2018.

17-CA-625 2 Kinnett v. Kinnett, 17-625 (La. App. 5 Cir. 8/6/20), 302 So.3d 157, 165, writ granted, 20-01134 (La. 2/9/21), 309 So.3d 735, reh’g denied, 20-01134 (La. 1/28/22), and writ granted, 20-01143 (La. 2/9/21), 309 So.3d 735, reh’g denied, 20-01143 (La. 1/28/22), and writ granted, 20-01156 (La. 2/9/21), 309 So.3d 738, reh’g denied, 20-01156 (La. 1/28/22), and rev’d in part, 20-01134 (La. 10/10/21), 332 So.3d 1149.

On remand, Mr. Andrews filed a first supplemental and amended petition to

properly raise a challenge to the constitutionality of La. C.C. art. 198. In the

supplemental petition, Mr. Andrews further set forth factual allegations to

demonstrate that he had “immediately assumed the role of G.J.K.’s biological

father and began taking steps to support…and become involved in G.J.K.’s life.”

Mr. Andrews set forth the following allegations:

Upon learning that he is, in fact, the father of the minor child, G.J.K., Petitioner [sic] [actually Intervenor–Mr. Andrews] immediately began to establish a relationship with G.J.K. and sought to see G.J.K. as much as possible. However, this was made extremely difficult by the circumstances then existing between Petitioner [Ms. Kinnett] and Defendant [Mr.

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

Related

Stanley v. Illinois
405 U.S. 645 (Supreme Court, 1972)
Lehr v. Robertson
463 U.S. 248 (Supreme Court, 1983)
People of Living God v. Chantilly Corporation
207 So. 2d 752 (Supreme Court of Louisiana, 1968)
In Re Melancon
935 So. 2d 661 (Supreme Court of Louisiana, 2006)
Parish Nat. Bank v. Wilks
923 So. 2d 8 (Louisiana Court of Appeal, 2005)
Phillips v. Gibbs
39 So. 3d 795 (Louisiana Court of Appeal, 2010)
Tracie F. v. Francisco D.
188 So. 3d 231 (Supreme Court of Louisiana, 2016)
Tracie F. v. Francisco D.
174 So. 3d 781 (Louisiana Court of Appeal, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Karen Cohen Kinnett Versus Jarred Brandon Kinnett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/karen-cohen-kinnett-versus-jarred-brandon-kinnett-lactapp-2022.