Kristen Lindsay Pruitt v. Kayla Nicole Williams

CourtCourt of Appeals of Virginia
DecidedJune 9, 2020
Docket1859193
StatusUnpublished

This text of Kristen Lindsay Pruitt v. Kayla Nicole Williams (Kristen Lindsay Pruitt v. Kayla Nicole Williams) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kristen Lindsay Pruitt v. Kayla Nicole Williams, (Va. Ct. App. 2020).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Beales, Huff and Senior Judge Annunziata UNPUBLISHED

KRISTEN LINDSAY PRUITT MEMORANDUM OPINION* v. Record No. 1859-19-3 PER CURIAM JUNE 9, 2020 KAYLA NICOLE WILLIAMS

FROM THE CIRCUIT COURT OF RUSSELL COUNTY Michael L. Moore, Judge

(Kimberly C. Haugh, on brief), for appellant. Appellant submitting on brief.

(Linda Tiller; Traci Stanley, Guardian ad litem for the minor children; Tiller and Tiller, P.C., on brief), for appellee. Appellee and Guardian ad litem submitting on brief.

Appellant, Kristen Lindsay Pruitt, appeals a final order of adoption. Appellant argues

that the circuit court erred by granting the petition for adoption and finding that she had withheld

her consent to the adoption contrary to the children’s best interests. Appellant further asserts that

the circuit court erred in finding that she had “abandoned the children during any time during

their lives.” Upon reviewing the record and briefs of the parties, we conclude that the circuit

court did not err. Accordingly, we affirm the decision of the circuit court.

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. BACKGROUND1

“Because the circuit court heard evidence ore tenus, its factual findings are ‘entitled to the

same weight accorded a jury verdict[] and . . . will not be disturbed on appeal unless plainly wrong

or without evidence to support’ them.” Geouge v. Traylor, 68 Va. App. 343, 347 (2017) (quoting

Bristol Dep’t of Soc. Servs. v. Welch, 64 Va. App. 34, 44 (2014)). We recite the evidence in the

light most favorable to appellee, Kayla Nicole Williams, as she prevailed in the circuit court. Id.

Appellant is the biological mother to the two children who are the subject of this appeal.

Appellee is the children’s stepmother and is married to the children’s biological father, Frank

Andrew Williams (father). On April 2, 2019, appellee filed a petition for adoption under Code

§ 63.2-12052 and alleged that appellant was withholding her consent to the adoption contrary to

the children’s best interests.3 After being served with the petition, appellant notified the circuit

court that she contested the adoption.

The parties appeared before the circuit court on August 9, 2019. After hearing the

parties’ evidence and arguments, the circuit court reviewed the standards delineated in Code

§ 63.2-1205 and found that appellant had withheld her consent to the adoption contrary to the

1 The record in this case was sealed. Nevertheless, the appeal necessitates unsealing relevant portions of the record to resolve the issues appellant has raised. Evidence and factual findings below that are necessary to address the assignments of error are included in this opinion. Consequently, “[t]o the extent that this opinion mentions facts found in the sealed record, we unseal only those specific facts, finding them relevant to the decision in this case. The remainder of the previously sealed record remains sealed.” Levick v. MacDougall, 294 Va. 283, 288 n.1 (2017). 2 Appellee also requested that the adoption be granted under Code § 63.2-1202(H) because appellant had not had contact with the children for more than six months before the filing of the petition for appeal. The circuit court rejected this request. 3 Father joined in appellee’s petition for adoption and consented to her adopting the children. -2- children’s best interests. The circuit court granted appellee’s petition for adoption and entered

the final order of adoption on October 17, 2019. Appellant timely noted her appeal.

ANALYSIS

Appellant argues that the circuit court erred by granting appellee’s petition for adoption and

finding that the evidence was sufficient to prove that she withheld her consent to the adoption

contrary to the children’s best interests.

Adequacy of the record

Appellant filed a written statement of facts in lieu of transcript; however, the filing was

untimely.4 See Rule 5A:8(c). Although the trial judge signed the written statement of facts in

lieu of transcript, it did not become part of the record on appeal because appellant failed to

comply with the filing requirements of Rule 5A:8(c). Anderson v. Commonwealth, 13 Va. App.

506, 508-09 (1992). “[A] written statement of facts becomes a part of the record only if all of the

requirements of Rule 5A:8 are complied with by the parties and the trial judge.” Id. at 508

(emphasis added) (quoting Mayhood v. Mayhood, 4 Va. App. 365, 368-69 (1987)). We have

examined the record and find that a timely-filed transcript or written statement of facts in lieu of

transcript is indispensable for resolving appellant’s third assignment of error, regarding the

circuit court’s finding that she had abandoned her children. Consequently, we do not address

that assignment of error. We find, however, that the record is adequate to address appellant’s

two remaining assignments of error. See Bay v. Commonwealth, 60 Va. App. 520, 528-29

(2012); Anderson, 13 Va. App. at 508-09.

4 The circuit court entered the final order on October 17, 2019. Under Rule 5A:8(c), a written statement of facts in lieu of transcript was due in the trial court within fifty-five days of entry of the final order, which in this case was Wednesday, December 11, 2019. Appellant, however, filed the statement of facts in lieu of transcript one day late, on December 12, 2019. -3- Merits of appellant’s remaining challenges to the circuit court’s order

“‘[T]he interest of parents in the care, custody, and control of their children . . . is perhaps

the oldest of the fundamental liberty interests recognized by’ the United States Supreme Court.”

Geouge, 68 Va. App. at 368 (quoting Troxel v. Granville, 530 U.S. 57, 65 (2000) (plurality

opinion)). “We have consistently held that to grant a petition for adoption over a birth parent’s

objection, there must be more than a mere finding that the adoption would promote the child’s best

interests.” Copeland v. Todd, 282 Va. 183, 197 (2011) (citing Malpass v. Morgan, 213 Va. 393,

398-99 (1972)). “Virginia’s statutory scheme for adoption, including Code §§ 63.2-1205

and -1208, defines the best interests of the child in terms that require more expansive analysis than

when the contest is between two biological parents.” Id. at 199.

Code § 63.2-1205 states, in relevant part, as follows:

In determining whether the valid consent of any person whose consent is required is withheld contrary to the best interests of the child, . . . the circuit court . . . shall consider whether granting the petition pending before it would be in the best interest of the child. The circuit court . . . shall consider all relevant factors, including the birth parent(s)’ efforts to obtain or maintain legal and physical custody of the child; whether the birth parent(s) are currently willing and able to assume full custody of the child; whether the birth parent(s)’ efforts to assert parental rights were thwarted by other people; the birth parent(s)’ ability to care for the child; the age of the child; the quality of any previous relationship between the birth parent(s) and the child and between the birth parent(s) and any other minor children; the duration and suitability of the child’s present custodial environment; and the effect of a change of physical custody on the child.

The record demonstrates that the circuit court considered the evidence presented and the

factors delineated in Code § 63.2-1205. The circuit court found that appellant had done “very little

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Related

Copeland v. Todd
715 S.E.2d 11 (Supreme Court of Virginia, 2011)
Phillip C. BAY, S/K/A Philip C. Bay v. COMMONWEALTH of Virginia
729 S.E.2d 768 (Court of Appeals of Virginia, 2012)
Troxel v. Granville
530 U.S. 57 (Supreme Court, 2000)
Malpass v. Morgan
192 S.E.2d 794 (Supreme Court of Virginia, 1972)
Mayhood v. Mayhood
358 S.E.2d 182 (Court of Appeals of Virginia, 1987)
Anderson v. Commonwealth
413 S.E.2d 75 (Court of Appeals of Virginia, 1992)
Patricia E. Smith, Guardian ad litem for the minor child v. Maggie S. Welch
764 S.E.2d 284 (Court of Appeals of Virginia, 2014)
MacDougall v. Levick
805 S.E.2d 775 (Supreme Court of Virginia, 2017)

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