Ramsey v. Harvey

75 Va. Cir. 220, 2008 Va. Cir. LEXIS 276
CourtSalem County Circuit Court
DecidedMay 7, 2008
DocketCase No. CL07-329
StatusPublished

This text of 75 Va. Cir. 220 (Ramsey v. Harvey) is published on Counsel Stack Legal Research, covering Salem County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramsey v. Harvey, 75 Va. Cir. 220, 2008 Va. Cir. LEXIS 276 (Va. Super. Ct. 2008).

Opinion

By Judge Robert P. Doherty, Jr.

Joint legal custody was granted as a result of the divorce. Mother obtained physical custody of the three children and father received visitation rights. Mother recently lost her job as a real estate agent because of the depressed real estate market. She now seeks to relocate to Arizona where she has family with whom she and the children will temporarily live and who will assist her in providing day care while she works. Mother has also obtained a job in Arizona selling new cars at a dealership. Father objects to the relocation, claiming that such a move will make it almost impossible for him to visit with the children frequently because of his financial situation. He argues that relocation will not be in the best interest of the children because it will harm the close bond and the loving relationship he has with them.

Mother contends that Father is an irresponsible, argumentative, and contentious ne’er do well, who puts his interests before those of the children; that he subjects them to his alcohol and marijuana use, as well as the marijuana use of others; that he routinely takes the children to construction sites at which he works; that he visits with the children at his convenience, not always when scheduled and not always with all of the children at the same time; that he frequently does not return the children at appropriate times and sometimes not even on the appropriate day; that he has at various times caused the children to be absent from, and tardy to, school; that he does not now, and [221]*221has not historically, provided the court ordered support for the children, even when they find themselves in necessitous circumstances; and that he has to be forced to pay child support under threat of incarceration after more than once going for a year or more in between payments. Mother believes that moving to Arizona will allow her to earn a reasonable living, provide for the children and herself, stabilize their lives, and give her reliable assistance from family members to help care for the children during times when she is at work. Nothing that Mother testified to concerning Father was complimentary.

The Court had the opportunity to observe and consider the appearance and maimer of the witnesses on the stand, their intelligence, their opportunity for knowing the truth and for having observed the things about which they testified, their interest in the outcome of the case, their bias and their prior inconsistent statements, and whether they have knowingly testified untruthfully as to any material fact in this case. In all instances where there was a conflict in the testimony between Father and Mother or Mother’s witnesses, the Court believed Mother and her witnesses. Father’s testimony was self-serving, misleading, evasive, and full of half-truths and false assertions. In short, he lied. When caught in apparent lies or half-truths, he gave alibis and tried to justify his actions by blaming others. This case will be decided mainly on the evidence given on behalf of Mother. The independent analysis and report of the children’s guardian ad litem and his unique perspective has been very helpful, although it does not control the Court’s decision in this case.

Relocation

The formula to be used when deciding a custody relocation case requires the Court to make specific factual findings in three areas. “[T]he court must find: (1) a material change in circumstances since the prior decree; and, (2) that relocation would be in the children’s best interest.” Wheeler v. Wheeler, 42 Va. App. 282, 288 (2004), quoting from Bostic v. Bostic-Bennett, 23 Va. App. 527, 535 (1996). See also § 20-124.3, Code of Virginia (1950), as amended, for the factors to be considered by the Court when determining the best interests of the child. In addition, (3) the relocation must not substantially impair the beneficial relationship between the child and the noncustodial parent. Scinaldi v. Scinaldi, 2 Va. App. 571, 575 (1986), and Sullivan v. Knick, 38 Va. App. 773, 783 (2002). If all three of these elements are established by the party seeking to remove the children from the state, relocation will be granted. If not, the request to relocate the children to another state will be denied.

[222]*222 Material Change in Circumstances

Unless a material change in circumstances occurs, no reason exists to alter a custody decision. Hughes v. Gentry, 18 Va. App. 318, 321 (1994). Res judicata prevents the Court from trying the same custody case over and over again. Only when something major occurs that affects the life of the children, will the Court reconsider its earlier custody decision. When determining whether such a major event or material change in circumstances has occurred, the Court makes a factual determination based on all of the evidence presented. Changed circumstances is viewed as a broad concept that encompasses all aspects of the child’s life, including both positive and negative developments and frequently including potential changes in the lives of their parents. Keel v. Keel, 225 Va. 606, 611-12 (1983).

Since the last custody order, because of the serious downturn in the real estate market, Mother has lost her job as a real estate agent. Father has repeatedly failed to provide child support. Mother has sold her home in anticipation of moving to Arizona with the children. Mother and children are now living in temporary quarters. Mother has been doing temporary construction work to provide for the daily food, clothing, and shelter needs of her and the children. Mother has a good job offer in Arizona, where she has family who will assist her in providing reliable care for the children while she works. This new job will include health insurance for the children and for Mother, which none of them have had recently. Both Mother and Father have been remarried, Mother having since divorced her most recent husband and Father having now separated from his most recent wife. Father is newly employed as an apartment maintenance worker, but ceased receiving income from his job because of an injury, although he still continues to repossess cars and conduct a construction business on the side. Father has purchased and maintains a vacation home with a partner on Smith Mountain Lake, but has had to sell at least one boat to pay his child support arrears last fall. Father either was, or is, being evicted from his rented residence and is currently in arrears in his rent and has had new judgments entered against him.

These are major developments that will have a serious impact on the lives of both the children and their parents. They sufficiently change the circumstances surrounding all of the parties affected by this litigation to the point that the principles of res judicata no longer come into play. Material changes in circumstances have been proven, and the Court is free to reexamine and reconsider its prior custody decision.

[223]*223 Best Interest of the Children

A relocation case is nothing more than a custody case where the primary caretaker is asking for the authority to move the children to a different state. That determination is based on whether or not the move is in the best interest of the children. Stockdale v. Stockdale, 33 Va. App. 179, 183 (2000). When deciding what is in the best interest of the children, the Court is required to consider those factors set forth in Va. Code § 20-124.3.

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Related

Philip Surles v. Kristan Mayer and Marty Cullen, Jr.
628 S.E.2d 563 (Court of Appeals of Virginia, 2006)
Wheeler v. Wheeler
591 S.E.2d 698 (Court of Appeals of Virginia, 2004)
Sullivan v. Knick
568 S.E.2d 430 (Court of Appeals of Virginia, 2002)
Stockdale v. Stockdale
532 S.E.2d 332 (Court of Appeals of Virginia, 2000)
Lee Trey Bostick v. Shannon T. Bostick-Bennett
478 S.E.2d 319 (Court of Appeals of Virginia, 1996)
Scinaldi v. Scinaldi
347 S.E.2d 149 (Court of Appeals of Virginia, 1986)
Keel v. Keel
303 S.E.2d 917 (Supreme Court of Virginia, 1983)
Hughes v. Gentry
443 S.E.2d 448 (Court of Appeals of Virginia, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
75 Va. Cir. 220, 2008 Va. Cir. LEXIS 276, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramsey-v-harvey-vaccsalem-2008.