Leanne Bridges v. James Bridges

CourtLouisiana Court of Appeal
DecidedJuly 3, 2024
DocketCA-0023-0763
StatusUnknown

This text of Leanne Bridges v. James Bridges (Leanne Bridges v. James Bridges) 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
Leanne Bridges v. James Bridges, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 23-763

LEANNE BRIDGES

VERSUS

JAMES BRIDGES

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 268,120 HONORABLE LOWELL C. HAZEL, DISTRICT JUDGE

GUY E. BRADBERRY JUDGE

Court composed of Elizabeth A. Pickett, Shannon J. Gremillion, D. Kent Savoie, Van H. Kyzar, Candyce G. Perret, Jonathan W. Perry, Sharon D. Wilson, Charles G. Fitzgerald, Gary J. Ortego, Ledricka J. Thierry, Guy E. Bradberry, and Wilbur L. Stiles, Judges.

AFFIRMED IN PART; REVERSED IN PART; AND REMANDED WITH INSTRUCTIONS.

Pickett, J., concurs in part and dissents in part for the reasons assigned by Judge Stiles. Savoie, J., concurs in part and dissents in part for the reasons assigned by Judge Stiles. Kyzar, J., concurs in part and dissents in part for the reasons assigned by Judge Stiles. Perry, J., concurs in part and dissents in part for the reasons assigned by Judge Stiles. Stiles, J., concurs in part, dissents in part, and assigns reasons. Howell D. Jones, IV Adam G. Huddleston Carolyn O. Hines Jones Law Partners P.O. Box 14558 Alexandria, LA 71315 (318) 442-1515 COUNSEL FOR PLAINTIFF/APPELLEE: Leanne Bridges

Kenneth A. Doggett, Jr. P.O. Drawer 13498 Alexandria, LA 71315 (318) 487-4251 COUNSEL FOR DEFENDANT/APPELLANT: James Bridges EN BANC.

James Bridges appeals a trial court judgment sustaining an exception of no

cause of action filed by his ex-wife, Leanne Bridges, after he filed a motion to

modify a physical custody schedule, seeking an additional three days per month of

time with his two minor daughters. Due to a conflict of rendered decisions regarding

the application of the law on visitation/physical custody within this court when joint

custody has been granted to the parents, this court renders the following en banc

decision.

FACTS

James and Leanne were married on October 27, 2007. Two daughters were

born of the marriage in 2011 and 2015. On May 19, 2020, the parties physically

separated. The parties were divorced on November 8, 2021. Although not a part of

the record before this court, both parties agree that on December 16, 2021, a

considered custody decree was rendered awarding the parties joint custody, with

Leanne designated the domiciliary parent. Judgment was signed on March 23, 2022.

According to the pleadings, James was granted visitation every other weekend with

the girls.

Prior to rendering the considered custody judgment, the trial court noted that

James was recovering from the use of methamphetamine and marijuana. It was also

noted that James exhibited destructive verbal behavior in front of the children.

On June 20, 2023, James filed a motion to modify the physical custody

schedule to increase his time with the girls by three days a month. In addition, he

sought the removal of a vague and arbitrary provision in the judgment, sought a rule

for contempt, and asked for a child support credit, should he be granted additional time with his daughters. James stated that he had provided three years of negative

hair follicle tests.

In response, Leanne filed an exception of no cause of action. In her exception,

Leanne alleged that the allegations made by James were insufficient to support a

modification of custody under the standard announced in Bergeron v. Bergeron, 492

So.2d 1193 (La.1986), since he sought to modify a prior considered decree. In

opposition, James argued that courts are allowed to tweak a physical custody

schedule even when the evidence will not support a change of custody under the

Bergeron standard.

A hearing on the exception of no cause of action was held on August 28, 2023.

A judgment was signed on September 12, 2023, granting the exception of no cause

of action and denying the motion for contempt. James then filed the present appeal.

APPLICABLE STANDARD

On appeal, James’ sole assignment of error is that the trial court erred in

granting Leanne’s exception of no cause of action. He argues that the heavy burden

of proof for modification of custody pronounced in Bergeron does not apply when

a party only seeks to modify the nature of the joint or sole physical custody

arrangment under a considered joint custody decree.

In Bergeron, the father sought sole custody after the mother was previously

awarded sole custody in the divorce judgment. The supreme court held that “the

change of circumstances rule, the heavy burden rule, and the appellate review

standard apply to any petition to modify custody, regardless of whether it is joint or

sole custody.” Id. at 1203. James argues that Bergeron did not distinguish between

physical custody or visitation and only analyzed whether the heavy burden of proof

applied to modification of considered legal custody decrees. James further argues

2 that the heavy Bergeron standard does not apply to actions seeking to modify

physical custody, that the burden of proof for an increase in physical custody is

whether it is in the best interests of the children, and that he has stated a cause of

action to increase visitation with his daughters.

The supreme court in Bergeron, 492 So.2d at 1200, held that the parent

seeking a change of custody after a considered decree has been rendered:

bears a heavy burden of proving that the continuation of the present custody is so deleterious to the child as to justify a modification of the custody decree, or of proving by clear and convincing evidence that the harm likely to be caused by a change of environment is substantially outweighed by its advantages to the child or by proving by clear and convincing evidence that the harm likely to be caused by a change of environment is substantially outweighed by its advantages to the child.

The supreme court further noted that this heavy burden rule was to “avoid the

uncertainty and instability that a best interest test alone would provide.” Id. at 1202.

The supreme court observed that when the legislature adopted the best interest

principle by Act No. 448 of 1977, it did not do away with the change of

circumstances rule, the heavy burden rule, and the appellate review standard when a

party seeks to modify custody. The best interests of the children rule applies to

determine the appropriate custody arrangement once the appropriate burden of proof

has been met.

In White v. Fetzer, 97-1266 (La.App. 3 Cir. 3/6/98), 707 So.2d 1377, writ

denied, 98-931 (La. 5/15/98), 719 So.2d 466, the father sought an increase in

visitation after the parties entered into a stipulated joint custody plan which included

a provision that the plan was to be treated as a considered decree. This court held

that the heavy Bergeron standard did not apply. This court explained that “visitation

is not strictly a ‘species of custody’” but has an independent basis in the civil code

citing La.Civ.Code art. 136, Revision Comments 1993(b). Id. at 1380. This court

3 went on to hold that “a showing that the change in visitation is in the best interest of

the child is sufficient.” Id.; Gerace v. Gerace, 05-1300 (La.App. 3 Cir. 4/5/06), 927

So.2d 622; Piccione v. Piccone, 09-300 (La.App. 3 Cir. 10/7/09), 20 So.3d 576, writ

denied, 09-2718 (La. 2/26/10), 28 So.3d 274; Beebe v. Delcambre, 16-17 (La.App.

3 Cir. 6/1/16), 194 So.3d 1214. In White, 707 So.2d at 1380, this court explained

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Related

Bergeron v. Bergeron
492 So. 2d 1193 (Supreme Court of Louisiana, 1986)
Evans v. Lungrin
708 So. 2d 731 (Supreme Court of Louisiana, 1998)
Piccione v. Piccione
20 So. 3d 576 (Louisiana Court of Appeal, 2009)
Ramey v. DeCaire
869 So. 2d 114 (Supreme Court of Louisiana, 2004)
White v. Fetzer
707 So. 2d 1377 (Louisiana Court of Appeal, 1998)
Francois v. Leon
834 So. 2d 1109 (Louisiana Court of Appeal, 2002)
DeSoto v. DeSoto
893 So. 2d 175 (Louisiana Court of Appeal, 2005)
Brantley v. Kaler
986 So. 2d 188 (Louisiana Court of Appeal, 2008)
Gerace v. Gerace
927 So. 2d 622 (Louisiana Court of Appeal, 2006)
Cedotal v. Cedotal
927 So. 2d 433 (Louisiana Court of Appeal, 2005)
Beebe v. Delcambre
194 So. 3d 1214 (Louisiana Court of Appeal, 2016)
Mason v. Mason
203 So. 3d 519 (Louisiana Court of Appeal, 2016)
Griffith v. Latiolais
48 So. 3d 1058 (Supreme Court of Louisiana, 2010)
Wing v. N. O. Public Service, Inc.
132 So. 526 (Louisiana Court of Appeal, 1931)
Roy v. Central Louisiana Healthcare System
719 So. 2d 466 (Supreme Court of Louisiana, 1998)

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