Oliver v. Oliver

61 Va. Cir. 88, 2003 Va. Cir. LEXIS 14
CourtVirginia Circuit Court
DecidedJanuary 27, 2003
DocketCase No. (Chancery) 178681
StatusPublished

This text of 61 Va. Cir. 88 (Oliver v. Oliver) is published on Counsel Stack Legal Research, covering Virginia Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oliver v. Oliver, 61 Va. Cir. 88, 2003 Va. Cir. LEXIS 14 (Va. Super. Ct. 2003).

Opinion

By Judge Robert W. Wooldridge, Jr.

This matter is before the Court on Defendant Jerry C. Oliver’s Special Appearance to challenge this Court’s exercise of personal jurisdiction over Mr. Oliver in the above referenced matter. Mr. Oliver objects to jurisdiction in this case on the basis that he was not a resident or domiciliary of the Commonwealth of Virginia at the time Mrs. Oliver filed the underlying Bill of Complaint for Separate Maintenance. Both parties have briefed the issue, and I took the matter under advisement following oral argument. Having considered the parties’ arguments and relevant statutes and case law, I find that this Court properly exercised personal jurisdiction over Mr. Oliver in this case, and thus Defendant’s Special Appearance and Motion to Dismiss this action is denied.

I find the facts relevant to the present motion to be as follows. Mr. and Mrs. Oliver wed in Rangoon, Burma, in 1995. Mr. Oliver was stationed in Burma as part of his employment with the United States Department of State. At the time of their marriage, in fact from 1979 through 1997, Mr. Oliver listed Arkansas as his “home of record” with the State Department. In 1997, Mrs. Oliver became pregnant. Shortly thereafter, Mr. Oliver requested and [89]*89received an assignment within the United States in order to provide better medical care for his wife during her pregnancy.

The Olivers moved to Brandy Station, Virginia, in August 1997. They purchased a home and resided in Brandy Station for eight months, during which, on September 30,1997, the Olivers’ first child was born. Also during this period, Mr. Oliver changed his “home of record” with the State Department to Virginia and obtained a Virginia driver’s license. Mrs. Oliver considers Virginia to be the Olivers’ home. Mrs. Oliver has never changed her Virginia voting registration or taxpayer status since 1997.

The Olivers sold their Virginia home in April 1998 and began a series of relocations to various duty stations according to Mr. Oliver’s State Department assignments. First, in April 1998, Mr. Oliver accepted an assignment in Sierra Leone, and Mrs. Oliver and their child returned to Burma. In November 1998, Mr. Oliver returned to Warrenton, Virginia, for a brief training assignment. (Neither party presented evidence as to the duration of this stay.) Sometime after that assignment, the Olivers reunited and moved to Yemen, where they resided for five months. They next resided in Bangladesh from February 1999 through February 2001. Finally, the Olivers lived in Bulgaria from February 2001 through June 2002. Notably, the Olivers filed joint Virginia income tax returns in 1999, 2000, and 2001.

In early March 2002, Mr. Oliver filed retirement papers with the State Department. Also during March 2002, Mr. Oliver instructed the State Department to stop deducting Virginia income tax from his salary and to start deducting Arkansas income tax instead. In that same month, while stationed in Bulgaria but present in the United States, Mr. Oliver traveled to Arkansas for one week. While in Arkansas, Mr. Oliver obtained an Arkansas driver’s license, library card, and voter registration card, and turned in his Virginia license plates to the Arkansas Department of Motor Vehicles. He did so intending to change his domicile to Arkansas. Mr. Oliver maintained no formal residence in Arkansas during this time; he used his attorney’s Arkansas address for the purposes of establishing his Arkansas domicile. During this same visit, Mr. Oliver filed a divorce action in an Arkansas court, which he later dismissed because he and his wife were not formally separated. Mr. Oliver testified that he did not consider he and Mrs. Oliver separated until June 3, 2002.

. In early April 2002, Mrs. Oliver and their child visited Mr. Oliver in Arkansas for a few days. The Olivers then returned to Bulgaria for a short while until Mr. Oliver was transferred back to the United States owing to the Olivers’ marital difficulties. In late May 2002, Mrs. Oliver returned to Virginia to find a job and a new family residence. She was followed by Mr. [90]*90Oliver and their child who arrived in Virginia on June 1,2002. At that time, Mr. Oliver was awaiting a new assignment with the State Department. The Olivers remained in a Virginia hotel for two nights. On June 3, 2002, Mrs. Oliver delivered to Mr. Oliver a letter and proposed custody agreement. Mr. Oliver then left Virginia with their child and began residing in a hotel in Washington, D.C. Mr. Oliver paid for the hotel with a credit card bearing his own name but his father’s Oklahoma address as Mr. Oliver he did not have any permanent residence or mailing address.

On June 5,2002, in connection with his retirement request, Mr. Oliver filed a form with the State Department directing his retirement pay to be direct-deposited to an Arkansas bank. At some point later, he withdrew his retirement request entirely. Mrs. Oliver testified that, while she and her husband had discussed his retirement over the years, he never mentioned retiring to Arkansas and she never agreed to move or change her domicile to that state.

Also on June 5, 2002, Mrs. Oliver served Mr. Oliver in person in the District of Columbia with a Bill of Complaint for separate maintenance, thereby instituting the present matter, and a notice to appear before the Court’s calendar control judge on Thursday, June 6, 2002, to set a date for a pendente lite hearing on custody and support.

After receiving service of the Bill of Complaint, Mr. Oliver remained at his Washington, D.C., hotel for a short time, then requested extended leave from the State Department and traveled to Arkansas. He remained in Arkansas for several weeks before being transferred to Pakistan, where he remains.

This Court held a pendente lite hearing on custody and support issues on June 27, 2002. Mr. Oliver did not appear at that hearing despite having actual notice of the June 27, 2002, hearing. See July 8,2002, Order, Ex. 1 at 5. During that proceeding, the Court found that it had jurisdiction over custody issues in this case under the Uniform Child Custody Jurisdiction and Enforcement Act (“UCCJEA”), Virginia Code §§ 20-146.1, etseq., because Virginia was the child’s “home state,” and over support issues under the Virginia Long-Arm Statute, Virginia Code § 8.01-328.1, because the Olivers had maintained a matrimonial domicile in Virginia. See id. at 3.1 The Court [91]*91also found that it had jurisdiction over support issues under the Uniform Interstate Family Support Act (“UIFSA”), Virginia Code §§ 20-88.32, etseq., because the Olivers’ child resided in Virginia as a result of Mr. Oliver’s actions. See id. at 7. The Court awarded Mrs. Oliver primary physical custody of their child and both child and spousal support. See July 8, 2002, Order.

Mr. Oliver, through counsel, appeared specially before this Court on August 28,2002, to challenge this Court’s exercise of jurisdiction in the July 8,2002, Order, and to move for a dismissal of this case. Mr. Oliver contends that he neither is nor was a resident or domiciliary of Virginia when Mrs. Oliver instituted this action. Mr. Oliver argues that he extinguished his Virginia domicile and established domicile in Arkansas in April 2002 by virtue of his presence in that state and his actions described above evidencing his intent to remain in Arkansas. Therefore, argues Mr.

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Bluebook (online)
61 Va. Cir. 88, 2003 Va. Cir. LEXIS 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliver-v-oliver-vacc-2003.