Luerica Fiffee v. Michael Jiggetts

CourtCourt of Appeals of Georgia
DecidedFebruary 18, 2020
DocketA20A0131
StatusPublished

This text of Luerica Fiffee v. Michael Jiggetts (Luerica Fiffee v. Michael Jiggetts) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Luerica Fiffee v. Michael Jiggetts, (Ga. Ct. App. 2020).

Opinion

FIRST DIVISION BARNES, P. J., MERCIER, J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

February 18, 2020

In the Court of Appeals of Georgia A20A0131. FIFFEE v. JIGGETTS.

BARNES, Presiding Judge.

Following the grant of her application for discretionary review, Luerica Fiffee

(the “mother”) appeals from the trial court’s denial of her motion to vacate a custody

modification order granting primary physical custody of the children to Michael

Jiggetts (the “father”). According to the mother, the trial court’s custody modification

order must be set aside because notice of the hearing conducted on the father’s

motion to modify custody was served on her counsel by facsimile, and, as a result, did

not satisfy the statutory requirements for service found in OCGA § 9-11-5 (b) and

constituted a nonamendable defect on the face of the record. We agree with the

mother and therefore reverse. The record reflects that the parties, who never married, have six minor children.

The mother moved to New York with the four youngest children, and the father

remained in Georgia with the two oldest children. In August 2018, the trial court

granted the parties joint legal custody of the children, awarded the mother primary

physical custody of the four youngest children, and awarded the father primary

physical custody of the two oldest children (the “Custody Order”).1 The trial court

also ordered the father to pay child support.

Less than a month later, on September 7, 2018, the father filed a verified

motion to vacate the Custody Order, motion for new trial, and motion to modify

custody and child support (the “Motion to Modify Custody”). In connection with his

Motion to Modify Custody, the father filed an affidavit asserting that additional

people were living in the mother’s apartment in New York and that the living

conditions were unsanitary and unsafe such that he should be granted primary

physical custody of all six children.

On September 25, 2018, the trial court entered an order scheduling a hearing

on the father’s Motion to Modify Custody for seven days later, on October 2, 2018

1 The trial court previously entered orders legitimating Jiggetts as the father of the six children.

2 (the “Scheduling Order”). The bottom of the one-page Scheduling Order contained

the notation “cc:” followed by the names of each party’s counsel and a telephone

number for each, and it is undisputed that the Scheduling Order was sent to counsel

by facsimile.

The hearing on the father’s Motion to Modify Custody was held on October 2,

during which neither the mother nor her counsel appeared.2 At the conclusion of the

hearing, the trial court ruled from the bench that it would vacate the Custody Order

and award primary physical custody of all six children to the father, and counsel for

the father stated that she would prepare an order to that effect.

Two days later, the mother’s counsel submitted a letter to the trial court

asserting that he had not learned of the October 2 hearing until after it occurred.

According to counsel, he received all facsimiles transmitted to his office as

attachments to emails, and he acknowledged that he received the trial court’s faxed

Scheduling Order through his email system. However, counsel stated that he had been

out of town from September 25 to October 1, had a backlog of accumulated emails,

and did not see the faxed Scheduling Order until after the October 2 hearing. Counsel

2 The only portion of the October 2 hearing transcript in the appellate record is a three-page excerpt containing the trial court’s ruling from the bench.

3 asserted that notice of the hearing had been insufficient and requested that a date be

scheduled for the mother to “make the trip [to Georgia] and be heard” on the father’s

Motion to Modify Custody, given that evidence had been presented by the father at

the hearing.

The trial court did not schedule an additional hearing in light of counsel’s

letter. Rather, on October 15, 2018, the trial court entered an order granting the

father’s Motion to Modify Custody, awarding the father primary physical custody of

all six children and ordering the mother to pay child support (the “Modification

Order”). The trial court recited that the Scheduling Order had been served on the

mother’s counsel on September 25, 2018, that a hearing on the father’s motions was

conducted on October 2, and that the mother and her counsel failed to appear at the

hearing. The trial court also included factual findings based in part on the evidence

heard during the October 2 hearing.3

3 The father asserts in his appellate brief that nothing in the Modification Order indicates that the trial court’s factual findings were based on evidence presented at the October 2 hearing, but the Modification Order includes the express recital, “The Court having considered the Motion and evidence presented, IT IS HEREBY ORDERED AND ADJUDGED,” which appears on the first page of the Order and precedes all of the court’s factual findings and legal conclusions. Furthermore, the trial court included factual findings in its Modification Order that went beyond the averments contained in the father’s affidavit or the verified statements contained in his Motion to Modify Custody. Specifically, the trial court found in its Modification Order that the mother has refused to

4 On November 13, 2018, the mother filed a motion to vacate the Modification

Order (the “Motion to Vacate”). Among other things, the mother argued that service

of the Scheduling Order on her counsel by facsimile was insufficient under OCGA

§ 9-11-5 (b),4 and that, as a result, the Modification Order should be vacated and the

mother afforded an opportunity to travel to Georgia and be heard on the custody

give the children’s medical information to the father, that the two oldest children in the father’s custody were “not only straight A students but also recipients of multiple awards for behavior, attendance and positive role models for their classmates, several having been received since the [original child custody] hearing in May [2018],” and that the mother “has access to the older children’s school records and teachers but has never met the teachers nor inquired about their educational well-being.” 4 OCGA § 9-11-5 (b) provides in part: Whenever under this chapter service is required or permitted to be made upon a party represented by an attorney, the service shall be made upon the attorney unless service upon the party is ordered by the court. Service upon the attorney or upon a party shall be made by delivering a copy to the person to be served or by mailing it to the person to be served at the person’s last known address or, if no address is known, by leaving it with the clerk of the court. As used in this Code section, the term “delivery of a copy” means handing it to the person to be served or leaving it at the person to be served’s office with a person in charge thereof or, if such office is closed or the person to be served has no office, leaving it at the person to be served’s dwelling house or usual place of abode with some person of suitable age and discretion residing therein.

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Luerica Fiffee v. Michael Jiggetts, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luerica-fiffee-v-michael-jiggetts-gactapp-2020.