Michael Cormier v. Kaitlyn Cormier

CourtLouisiana Court of Appeal
DecidedOctober 20, 2021
DocketCA-0021-0234
StatusUnknown

This text of Michael Cormier v. Kaitlyn Cormier (Michael Cormier v. Kaitlyn Cormier) 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
Michael Cormier v. Kaitlyn Cormier, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

21-234

MICHAEL CORMIER

VERSUS

KAITLYN CORMIER

************ APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF IBERIA, DOCKET NO. 133400 HONORABLE LEWIS H. PITMAN, DISTRICT JUDGE

************ SYLVIA R. COOKS CHIEF JUDGE ************

Court composed of Sylvia R. Cooks, Chief Judge, John E. Conery and Jonathan W. Perry, Judges.

AFFIRMED.

Alicia Johnson Butler P.O. Box 9097 New Iberia, LA 70562 (337) 967-8487 COUNSEL FOR PLAINTIFF/APPELLANT: Michael Cormier

Scott Hawkins 913 South College Rd., Suite 260 Lafayette, LA 70503 (337) 210-8818 COUNSEL FOR DEFENDANT/APPELLEE: Kaitlyn Cormier COOKS, Chief Judge.

The plaintiff, Michael Cormier, appeals the trial court’s grant of the exception

of lack of subject matter jurisdiction filed by his ex-wife, Kaitlyn’ Cormier. For the

following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

Michael and Kaitlyn Cormier were married on March 8, 2012. They had one

child during their marriage, Khloe Cormier, who was born on March 23, 2012.

There was a history of incidents of domestic violence against Kaitlyn. On more than

one occasion Kaitlyn was granted a protective order against Michael stemming from

alleged violent and abusive behavior. Specifically on December 4, 2018, after

receiving evidence on this matter, the district court entered an order of protection

pursuant to La.R.S. 46:2131 against Michael and in favor of Kaitlyn. That order of

protection was to last through June 4, 2020, with certain provisions to be non-

expiring, specifically the provisions not to harass, not to contact via a third party and

not to go within two hundred feet.

On December 6, 2018, only two days after its issuance, Michael was arrested

for violating the protective order. A “Gwen’s Law” hearing was held on December

11, 2018, following which a $25,000.00 bond was fixed and Michael again was

ordered to have no contact with his wife and child.1 On January 12, 2019, Michael

was arrested a second time for violating the protective order. These violations are

still outstanding and have not been resolved.

On March 11, 2019, a consent judgment was entered into between Michael

and Kaitlyn awarding sole custody of Khloe to Kaitlyn, and requiring Michael’s

1 Under “Gwen's Law,” La.Code Crim.P. art. 313, the trial court is required to conduct a contradictory hearing to determine the feasibility of granting bail to a person arrested on domestic abuse charges. State v. Poirier, 18-467 (La.App. 3 Cir. 7/11/18), 251 So.3d 486. If the trial court finds that there is a likelihood that the defendant would inflict further harm, bail can be denied and the defendant would stay in jail until the case is heard in court. La.Code Crim.P. art. 313(A)(4). access to Khloe be “coordinated and structured under the supervision and direction”

of the mental health professionals treating Khloe and Michael. The Consent

Judgment also provided a “permanent injunction shall issue herein, pursuant to

[La.R.S.] 9:372, prohibiting and enjoining both of the parties from abusing,

harassing, stalking, following or threatening each other.”

On April 24, 2019, the Iberia Parish District Court granted a Judgment of

Divorce pursuant to La.Civ.Code art. 103(5)2 as well as an order of protection

pursuant to La.R.S. 42:2131. The judgment of divorce also adopted the

recommendations of the hearing officer (which were reflected in the March 11, 2019

Consent Judgment) as to ancillary issues, including the granting to Kaitlyn of sole

custody of Khloe, with Michael allowed supervised visitation at the discretion of the

mental health professionals. The judgment of divorce also decreed a “permanent

injunction is issued pursuant to La.R.S. 9:372.1 against Michael Brandon Cormier,

enjoining him and his agents from committing any form of harassment against

Kaitlyn Marie Cormier.”

In January 2020, Kaitlyn relocated to the state of Missouri. Despite this move,

Kaitlyn alleged Michael continued to stalk and harass her and Khloe. As a result,

Kaitlyn sought an order of protection in Missouri on February 27, 2020.

On February 18, 2020, in district court in Iberia Parish, Michael filed a

“Motion for Civil Warrant, Modification for Custody to Sole Custody, Visitation,

Child Support, Contempt, Request for Mental Health Evaluations and for Return of

Community Vehicle.” In response, Kaitlyn filed exceptions of insufficiency of

citation and service of process, lack of subject matter jurisdiction, vagueness and

ambiguity and no cause of action. A hearing was set on the exceptions. After

2 Louisiana Civil Code Article 103(5) provides for a fault-based judgment of divorce when “after a contradictory hearing or consent decree, a protective order or an injunction was issued during the marriage against the other spouse to protect the spouse seeking a divorce or a child of one of the spouses from abuse.” accepting memoranda on the issues and hearing arguments from the parties, the trial

court granted the exception of lack of subject matter jurisdiction and denied the

remaining exceptions as moot. The trial court found because there was a valid order

of protection issued pursuant to La.R.S. 9:372, Kaitlyn did not have to provide

notification to Michael or the court to relocate Khloe from Louisiana to Missouri.

Finding Kaitlyn and Khloe had lived in Missouri for six consecutive months, the

trial court concluded Louisiana no longer had subject matter jurisdiction. This

appeal followed. Michael contends the trial court erred in granting the exception of

lack of subject matter jurisdiction. For the following reasons, we affirm the trial

court’s judgment.

ANALYSIS

The facts are clear that a valid order of protection pursuant to La.R.S. 46:2131

was entered against Michael on December 4, 2018. That order of protection was to

last through June 4, 2020, with certain provisions to be non-expiring, which included

the provisions not to harass Kaitlyn, not to contact via a third party and not to go

within two hundred feet of Kaitlyn.

On April 24, 2019, a judgment of divorce was rendered pursuant to

La.Civ.Code art. 103(5). That judgment adopted the language of the prior Consent

Judgment reciting that Kaitlyn was awarded sole custody of Khloe. Sole custody to

Kaitlyn was mandated under the provisions of La.R.S. 9:364, which provides “no

parent who has a history of perpetrating family violence shall be awarded sole or

joint custody of children.” An order of protection pursuant to La.R.S. 42:2131 was

also issued in favor of Kaitlyn and against Michael.

The record also established Kaitlyn moved to Missouri in January of 2020.

This relocation was the basis for Kaitlyn’s argument that Louisiana no longer had

subject matter jurisdiction to hear Michael’s February 18, 2020 Motion. In the main,

Michael argues that the relocation provisions set forth in La.R.S. 9:355.1, et seq., required Kaitlyn to get either Michael’s permission or judicial approval to relocate

to Missouri with Khloe. However, as the trial court noted, La.R.S. 9:355.2(d)(2)

specifically provides “[t]his Subpart shall not apply when either of the following

circumstances exist: . . .

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Related

Guinn v. Kemp
136 So. 764 (Louisiana Court of Appeal, 1931)
State v. Poirier
251 So. 3d 486 (Louisiana Court of Appeal, 2018)

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Bluebook (online)
Michael Cormier v. Kaitlyn Cormier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-cormier-v-kaitlyn-cormier-lactapp-2021.