Rachel Sutton v. Vegas Higdon

CourtCourt of Appeals of Kentucky
DecidedDecember 19, 2025
Docket2024-CA-0964
StatusUnpublished

This text of Rachel Sutton v. Vegas Higdon (Rachel Sutton v. Vegas Higdon) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rachel Sutton v. Vegas Higdon, (Ky. Ct. App. 2025).

Opinion

RENDERED: DECEMBER 19, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2024-CA-0964-MR

RACHEL SUTTON APPELLANT

APPEAL FROM GRAYSON CIRCUIT COURT v. HONORABLE KENNETH H. GOFF, II, JUDGE CASE NO. 23-CI-00203

VEGAS HIGDON; ASHLEY HIGDON; AND DYLAN HIGDON APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, KAREM, AND MOYNAHAN, JUDGES.

KAREM, JUDGE: Rachel Sutton appeals from the Grayson Circuit Court’s

amended findings of fact, conclusions of law, and judgment regarding the custody

of her minor child. The circuit court found that the child’s paternal grandfather

and his wife qualify as de facto custodians. It awarded them joint custody and the

majority of parenting time. Upon careful review, we affirm. FACTUAL AND PROCEDURAL BACKGROUND

Rachel Sutton (“Rachel”) gave birth to E.H. (“Child”) in May 2022.

She and Child’s biological father, Dylan Higdon (“Dylan”), are not married.

Dylan’s father, Vegas Higdon, is married to Ashley, who is Dylan’s stepmother

(“the Higdons”).

Although the recording of the district court proceedings is not in the

record before us, the parties do not dispute that a dependency, neglect, and abuse

(“DNA”) action regarding Child was filed against Rachel in Breckenridge District

Court in July 2022. The primary reason for the action was Rachel’s alcohol

dependency and abuse. Child was removed from the home and placed in Dylan’s

custody. A DNA action was subsequently filed against Dylan for drug dependency

and abuse, and the district court ordered Child to be placed in the temporary

custody of the Higdons.

Child resided with the Higdons for approximately eighteen months,

from July 2022 until December 15, 2023. During this period, Rachel was working

on a case plan prepared for her by the Cabinet for Health and Family Services.

About five months after Child was placed in the Higdons’ custody, Rachel began

to file successive motions in district court for a return of custody of Child, all of

which were denied: (1) motion filed on November 22, 2022, denied on November

28, 2022; (2) motion filed on February 28, 2023, denied on March 6, 2023; (3)

-2- motion filed on March 14, 2023, denied on March 20, 2023; (4) motion filed on

May 1, 2023, denied on May 8, 2023; and (5) motion filed on September 12, 2023,

denied on October 9, 2023. Following a scheduled review, the district court

entered an order on December 8, 2023, returning custody to Rachel and Dylan

effective on December 15, 2023.

Meanwhile, on January 23, 2023, prior to Rachel’s second motion for

custody of Child filed in February, the Higdons filed a petition seeking de facto

custodian status and primary residential custody of Child. The petition was

ultimately dismissed by agreed order.1

On September 21, 2023, the Higdons filed another petition for custody

of Child or, in the alternative, for grandparent visitation. Following a hearing, the

Domestic Relations Commissioner (“DRC”) found that the Higdons qualified as de

facto custodians under Kentucky Revised Statutes (“KRS”) 403.270(1)(a), and

recommended the circuit court grant them this status. On April 3, 2024, the circuit

court entered an order adopting the DRC’s findings of fact, conclusions of law, and

order.

The DRC thereafter conducted a hearing to determine custody and

parenting time and issued recommendations on May 10, 2024. Rachel and Dylan

1 Rachel claims that the agreed order dismissed the petition with prejudice whereas the Higdons assert it was without prejudice. Rachel did not raise this as grounds for opposing the Higdons’ second petition for custody and consequently the issue was waived.

-3- filed exceptions. Following a hearing on the exceptions, the circuit court entered

findings of fact, conclusions of law, and judgment in accordance with the DRC’s

recommendations. It awarded joint custody of Child to Rachel and Dylan and to

the Higdons. Child was to reside primarily with the Higdons; Rachel and Dylan

were awarded parenting time every other weekend and every Tuesday from 6 pm

until Wednesday at 8:15 am. Rachel filed a Kentucky Rules of Civil Procedure

(“CR”) 59.05 motion to alter, amend, or vacate. She also filed a notice of appeal

before the circuit court had ruled on the motion to alter, amend, or vacate. This

Court ordered the appeal held in abeyance until the circuit court ruled on the post-

judgment motion. On September 9, 2024, the circuit court entered amended

findings of fact, conclusions of law, and judgment. This Court returned the appeal

to the active docket.

STANDARD OF REVIEW

“A custody determination is a mixed question of fact and law

requiring a two-tier analysis.” Ball v. Tatum, 373 S.W.3d 458, 463 (Ky. App.

2012). “First, we review a trial court’s factual findings, disturbing them only if

they are clearly erroneous – meaning they are unsupported by substantial evidence

which is defined as that which is sufficient to induce conviction in the mind of a

reasonable person.” Id. at 463-64 (internal quotation marks and citation omitted).

“Second, we examine the trial court’s application of the law de novo.” Id. at 464.

-4- ANALYSIS

Rachel argues that the circuit court erred; (i) in awarding the Higdons

de facto custodian status; (ii) in failing to give sufficient weight to evidence that

was favorable to her; (iii) in adopting the Higdons’ tendered judgment; (iv) in

holding that the presumption of equal parenting time was overcome; and (v) in not

maximizing her parenting schedule to afford her more time with Child.

(i) The circuit court did not err in holding that the Higdons met the definition of de facto custodians

A de facto custodian is defined as:

[A] person who has been shown by clear and convincing evidence to have been the primary caregiver for, and financial supporter of, a child who within the last two (2) years has resided with the person for an aggregate period of six (6) months or more if the child is under three (3) years of age and for an aggregate period of one (1) year or more if the child is three (3) years of age or older or has been placed by the Department for Community Based Services. Any period of time after a legal proceeding has been commenced by a parent seeking to regain custody of the child shall not be included in determining whether the child has resided with the person for the required minimum period.

KRS 403.270(1)(a).

Once a court “determines by clear and convincing evidence that the

person meets the definition of de facto custodian . . . the court shall give the person

the same standing in custody matters that is given to each parent under this

section[.]” KRS 403.270(1)(b).

-5- The standard to achieve de facto custodian status is very high, because

“[t]he courts of this Commonwealth have consistently recognized the superior right

of natural parents to the care, custody, and control of their children as well as the

constitutionally protected right of a parent to raise his or her own child.”

Brumfield v. Stinson, 368 S.W.3d 116, 118 (Ky. App. 2012).

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