Rawlings v. Rawlings

Procedural entryThis page is a short order in Rawlings v. Rawlings. Read the opinion of the Court — 548 P.3d 43
New Mexico Supreme Court·Decided February 19, 2024·Unpublished

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: February 19, 2024

4 NO. S-1-SC-39107

5 KEVIN RAWLINGS,

6 Petitioner-Petitioner,

7 v.

8 MICHELLE RAWLINGS,

9 Respondent-Respondent.

10 ORIGINAL PROCEEDING ON CERTIORARI 11 Angie K. Schneider, District Judge

12 Rodey, Dickason, Sloan, Akin & Robb, P.A. 13 Jocelyn C. Drennan 14 Albuquerque, NM

15 Erinna Marie Atkins 16 Alamogordo, NM

17 for Petitioner

18 Durham, Pittard & Spalding, LLP 19 Caren I. Friedman 20 Justin R. Kaufman 21 Rosalind B. Bienvenu 22 Santa Fe, NM

23 Egolf Ferlic Martinez Harwood LLC 1 Kristina Martinez 2 Santa Fe, NM

3 for Respondent 1 OPINION

2 THOMSON, Justice.

3 I. INTRODUCTION

4 {1} Rule 1-053.2(H) NMRA instructs district court judges and litigants on the

5 required procedure following receipt of the domestic relations hearing officer’s

6 recommendations. This case answers whether Rule 1-053.2 NMRA (2017)1 requires

7 a district court to hold an in-person hearing to resolve a party’s objections to the

8 hearing officer’s recommendations in a domestic relations proceeding. Additionally,

9 this case clarifies the district court’s requirement to set forth a reasoned basis for its

10 resolution of these objections. See Buffington v. McGorty, 2004-NMCA-092, ¶ 31,

11 136 N.M. 226, 96 P.3d 787 (“[T]he record of the hearing held before the district

12 court must demonstrate that the court in fact considered the objections and

13 established the basis for the court’s decision.”).

1 The events relevant to this appeal occurred prior to this Court’s approved amendment to Rule 1-053.2, effective December 31, 2022, which makes clear that an in-person hearing is not required. Rule 1-053.2(H)(2)(a). Therefore, further reference in this opinion is to Rule 1-053.2 (2017) (taking “effect[] for all cases pending or filed on or after December 31, 2017”). This 2017 version is also identified as “the Rule” throughout this opinion. 1 {2} Having granted Father’s petition for certiorari, we conclude the language of

2 Rule 1-053.2 (2017) does not require a district court to hold an in-person hearing. In

3 addition, we conclude that the district court set forth a reasoned basis for resolving

4 Mother’s objections to the hearing officer’s recommendations when it independently

5 reviewed the record and adopted, modified, or rejected the hearing officer’s

6 recommendations in the final order. Further, the district court complied with Rule 1-

7 060(A) NMRA in exercising jurisdiction to clarify the record and amend the final

8 decree while this case was on appeal.

9 II. BACKGROUND

10 {3} Kevin Rawlings (Father) and Michelle Rawlings (Mother) separated in

11 November 2015. Mother moved from Alamogordo, New Mexico, to Las Vegas,

12 Nevada, with the parties’ two young children. Father filed a petition for dissolution

13 of marriage on January 26, 2016. Among their many disputes, the parties disagreed

14 about who should have the primary physical custody of the children. The district

15 court referred the case to a domestic relations hearing officer. The hearing officer

16 reviewed evidence and heard argument on all disputed issues, including issues

17 relating to physical custody of the children, before filing a recommendation on the

18 merits, which included detailed findings and conclusions. The hearing officer

19 determined that “Joint Legal Custody [wa]s proper in this case” and that it was “in

2 1 the best interest of the . . . children to reside primarily in New Mexico with [Father].”

2 Within ten days, Mother’s filing in response raised over forty objections to the

3 hearing officer’s recommendations, along with additional evidence, and requested a

4 hearing on her objections with the district court. Father filed a response and asked

5 the court to adopt the recommendations and enter a final decree of dissolution of

6 marriage and division of assets, debts and custody.

7 {4} The district court did not hold an in-person hearing on Mother’s objections

8 and instead entered a final decree of dissolution of marriage that generally adopted

9 the hearing officer’s recommendations. The final decree did not address Mother’s

10 objections. Mother filed a notice of appeal and a motion to stay enforcement of the

11 judgment pending appeal. At a hearing on the motion to stay, the district court

12 explained the court’s resolution of Mother’s objections on the record stating,

13 I wanted to make a record . . . with regard to the objection and to my 14 adopting the recommendations . . . . While I am required to review the 15 recommendations and make an independent determination of whether 16 or not I’m going to adopt those recommendations, I don’t read [Rule 1- 17 053.2 (2017)] to require a hearing. I read the Rule to require a hearing 18 . . . if I deem it is necessary to resolve the objections. And in my review 19 of the record and my independent review of the recommendations . . . , 20 and the objections filed and the response . . . , I made a determination 21 that a hearing was not necessary for me to resolve anything. And so I 22 adopted [the hearing officer’s] recommendations. . . . I felt that the 23 objections really were a disagreement with what [the hearing officer] 24 ruled. . . . I felt I needed to make that record clear for the parties, for 25 counsel, for the higher court.

3 1 {5} Father suggested that an in-person hearing is not required and that the district

2 court conducted a hearing according to the Rule when the court independently

3 reviewed the record and adopted the hearing officer’s recommendations. Father

4 requested the filing of an amended final decree that would reflect the court’s

5 compliance with Rule 1-053.2 (2017) and orally moved the court to amend the final

6 decree under Rule 1-060(A), arguing that the omission of the court’s process for

7 resolving objections in the final decree was a “clerical mistake.” Following the

8 hearing, the district court denied Mother’s motion for stay, granted Father’s oral

9 motion to amend the final decree, and entered an amended final decree. The amended

10 final decree added that the court

11 conducted an independent review hearing under [Rule] 1- 12 053.2(H)(1)(b) [(2017)], which included proper review of [Mother’s] 13 Objections, an independent review of the record, an independent 14 determination that an additional evidentiary hearing and oral argument 15 was unnecessary, and the Court . . . made an independent determination 16 to approve and adopt the Recommendations of the Hearing Officer.

17 The amended final decree also denied Mother’s objections. Mother appealed.

18 {6} The Court of Appeals reversed the district court’s initial and amended final

19 decree, concluding that the district court judge did not comply with Rule 1-053.2

20 (2017), Rawlings v. Rawlings, 2022-NMCA-013, ¶¶ 1, 27, 505 P.3d 875, and

21 asserting two grounds for error. First, the Court’s majority held that the Rule

4 1 mandated an in-person hearing. Id. ¶¶ 15, 25. Second, because it did not hold an in-

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