Lauren Lee v. Beau Bramlett

CourtCourt of Appeals of Mississippi
DecidedFebruary 26, 2019
Docket2017-CA-01202-COA
StatusPublished

This text of Lauren Lee v. Beau Bramlett (Lauren Lee v. Beau Bramlett) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lauren Lee v. Beau Bramlett, (Mich. Ct. App. 2019).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2017-CA-01202-COA

LAUREN LEE APPELLANT

v.

BEAU BRAMLETT APPELLEE

DATE OF JUDGMENT: 08/08/2017 TRIAL JUDGE: HON. M. RONALD DOLEAC COURT FROM WHICH APPEALED: LAMAR COUNTY CHANCERY COURT ATTORNEY FOR APPELLANT: WILLIAM C. WALTER ATTORNEYS FOR APPELLEE: ROBERT R. MARSHALL KIMBERLY-JOY LOCKLEY MIRI NATURE OF THE CASE: CIVIL - CUSTODY DISPOSITION: AFFIRMED - 02/26/2019 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

BARNES, C.J., FOR THE COURT:

¶1. Lauren Lee and Beau Bramlett are the natural parents of a minor child, Gregory,1 born

out of wedlock in 2010. For the first four years of the child’s life, Lee and Gregory lived

with Bramlett at his residence in Hattiesburg, Mississippi. Bramlett worked offshore for

three-week intervals (twenty-one days on/twenty-one days off); Lee primarily stayed at home

with Gregory but occasionally worked at a part-time job. In May 2015, the couple ended

their relationship, and Lee filed a complaint to establish child custody, seeking child support

and temporary and permanent legal and physical custody of Gregory. Acknowledging he was

1 A fictitious name has been used for the minor child to protect his identity. the child’s natural father, Bramlett requested emergency custody.

¶2. In a temporary order, the Lamar County Chancery Court adjudicated Bramlett as the

natural father and ordered the parties to share physical custody of Gregory on a week-to-

week basis. Bramlett was ordered to pay Lee monthly child support of $1,000 and to provide

medical insurance for the child. On September 16, 2016, the chancery court appointed

Stacey Sims as the guardian ad litem (GAL). Kristin McGee was later substituted as the

GAL.

¶3. On June 10, 2017, Lee moved to Madison, Mississippi, with her fiancé, Matthew

Pringle, and their newborn daughter so Pringle could start a new job.2 A few days later, Lee

and Pringle were married. Bramlett filed a petition for emergency relief requesting

permanent physical custody of Gregory. A trial was held June 29, 2017, and July 31, 2017.

Lee admitted Gregory had an extensive family-support system in Hattiesburg and was doing

well in his school there. But she argued that she should be given primary physical custody

because she is a stay-at-home mother and that Gregory would do equally well in the Madison

County School District. Lee also noted Bramlett’s work schedule as a reason she should

have custody. Bramlett, who has worked offshore in three-week intervals for fifteen years,

testified that he earned a very good income at his job, enabling him to provide financially for

all of Gregory’s needs. Bramlett also said he could not earn a comparable income if he

changed jobs to be home more often. His parents, who live nearby, testified they would take

care of Gregory when Bramlett was away at work. Bramlett also lived with his fiancée (now

2 Lee had been dating Pringle since she separated from Bramlett in May 2015.

2 wife) who could take care of Gregory.

¶4. The chancery court entered its opinion and final judgment on August 8. Considering

the Albright3 factors in conjunction with the GAL’s report, the court awarded primary

physical custody to Bramlett and joint legal custody to both parties. Lee was granted

visitation every other weekend. Lee appeals the chancery court’s decision. Finding no

manifest error in the court’s ruling, we affirm.

STANDARD OF REVIEW

¶5. “This Court will only reverse a chancery court’s decision ‘if it was manifestly wrong

or clearly erroneous, or if the chancellor applied an erroneous legal standard.’” Mitchell v.

Mitchell, 180 So. 3d 810, 815 (¶6) (Miss. Ct. App. 2015) (quoting Smith v. Smith, 97 So. 3d

43, 46 (¶7) (Miss. 2012)). We review questions of law de novo. Id. (citing Irving v. Irving,

67 So. 3d 776, 778 (¶11) (Miss. 2011)).

DISCUSSION

I. Whether the chancery court erred in disregarding the natural parent presumption.

¶6. A “bedrock principle of Mississippi family law” is the natural parent presumption,

which gives preference to a child’s natural parents, “even against those who have stood in

their place, honor[ing] and protect[ing] the fundamental right of natural parents to rear their

children.” Neely v. Welch, 194 So. 3d 149, 155 (¶19) (Miss. Ct. App. 2015). It is not

disputed that Bramlett is Gregory’s natural parent. However, Lee argues that because

Bramlett works offshore and must rely on his parents and his wife to care for the child during

3 Albright v. Albright, 437 So. 2d 1003 (Miss. 1983).

3 that time, the chancery court’s ruling essentially constituted “a de facto award of custody

and/or visitation rights to the grandparents over [Lee] who was expressly found to be a fit

parent.”

¶7. Custody was awarded to Bramlett, Gregory’s natural father. Bramlett’s parents were

not a party to this proceeding and have no custody rights under the order. The chancery court

and GAL simply factored the paternal grandparents into the custody analysis because they

volunteered to provide child care when Bramlett is working. There are no Mississippi cases

on point with these facts, but we find instructive a holding by the South Carolina Court of

Appeals. In Brown v. Brown, 606 S.E.2d 785, 791 (S.C. Ct. App. 2004), the court expressly

rejected the principle of “de facto” custody where the father, who was awarded physical

custody, worked long late-night shifts and lived with his parents. Similarly, in Burns v.

Burns, No. COA10-50, 2011 WL 531473, **7-8 (N.C. Ct. App. Feb. 15, 2011), the North

Carolina Court of Appeals found that although the minor children were often in the care of

the paternal grandparents while in the father’s custody, the grandparents had no rights under

the trial court’s order, “much less . . . any kind of ‘de facto custody’ of the minor children or

any other legally enforceable rights.”

¶8. The dissent agrees with Lee, finding that she “should have been favored in a custody

analysis to provide care instead of the paternal grandparents.” Applying the dissent’s

reasoning, no parent who works offshore or out-of-town for extended periods of time would

be granted custody without a finding that the other parent is unfit or has abandoned the child.

We cannot adopt such a general rule as it disregards the chancery court’s responsibility to

4 decide what is in the best interest of the child. Here, it is clear that custody was awarded to

Bramlett, not his parents; therefore, the “natural parent presumption” applies equally to Lee

and Bramlett. And, while the dissent is correct that Gregory lived with Lee for the first six

years of his life, it fails to mention that Bramlett also lived in the home for the first four years

of the child’s life. The record further shows that both parties have extended family living in

the Hattiesburg area; Lee’s move to Madison uprooted Gregory not only from his father, but

also from these close relatives. Bramlett’s mother testified that before Bramlett and Lee

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