Reynolds v. Reynolds

21 Pa. D. & C.5th 246
CourtPennsylvania Court of Common Pleas, Lebanon County
DecidedFebruary 4, 2011
Docketno. 2010-20866
StatusPublished

This text of 21 Pa. D. & C.5th 246 (Reynolds v. Reynolds) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lebanon County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reynolds v. Reynolds, 21 Pa. D. & C.5th 246 (Pa. Super. Ct. 2011).

Opinion

CHARLES, J.,

Yomaris Reynolds (hereafter “wife”) has filed a motion seeking exclusive possession of a home that is titled solely in her name. Donald E. Reynolds (hereafter “husband”) seeks to use his status as a husband in order to remain in the house that has been his home since the parties married. For reasons that we will articulate in more detail within this opinion, we will be granting wife’s request for exclusive possession to be effective on April 1, 2011.

I. FACTS

On November 4, 2010, wife filed a complaint for divorce against husband. The complaint alleged that the marriage was irretrievably broken. At the time the complaint was filed, both parties lived inside a house at 204 East Walnut Street, Lebanon, Lebanon County, Pennsylvania (said real estate will hereafter be referred to as “residence”). At or near the time the divorce complaint [248]*248was filed, wife moved to a separate bedroom within residence.

Residence had been purchased by wife in May of 2002 before she and husband became married. Husband did not contribute toward the purchase price of residence, although he says that he invested money in maintenance and repair of residence during the course of the marriage. At all times pertinent hereto, residence remained titled in wife’s sole name.

Both husband and wife enjoy good jobs in the healthcare industry. Wife’s job as a pharmacy technician at the Good Samaritan Hospital requires her to work Monday through Friday until 11:00 p.m. Husband works at Hershey Medical Center. Flis job begins at 3:30 p.m. and extends until roughly 3:30 a.m. On a typical day, wife would arrive home from work between 11:00 p.m. and 11:30 p.m. and husband would return home from work at about 4:00 a.m.

During the marriage, there were times when husband and wife would enjoy each other’s company in the early morning hours after husband returned home from work. As the marriage soured, wife began her sleep period shortly after she returned home from work. In or about October of 2010, wife began sleeping in a separate bedroom and would be fast asleep when husband returned from work at about 4:00 a.m.

Wife’s daughter is Esther Vallejo (hereafter “Esther”). Esther is a recent graduate of Penn State University. She works part-time as a human relations representative and interpreter at Hershey Foods. Esther is pregnant.

[249]*249Esther moved back to residence following her graduation from Penn State. She testified that her mother moved into her bedroom in or about October/ November of 2010. She also stated that on a nearly daily basis, husband would awaken she and wife when he returned home from work by turning on all of the lights in the home, coming into their bedroom, turning on the laundry machine and generally acting in a way that would ensure that occupants inside the home would awaken. Esther stated that she told husband to cease and desist this behavior “almost every day.”

Esther stated that things became so bad that she had her boyfriend, Corey Reed, move into residence. Mr. Reed is an ex-marine who is now a full-time student at Penn State University. Reed testified that since he moved into residence in January of 2011, there have been no problems with loud and boisterous behavior by husband at 4:00 a.m.

During the course of the marriage, husband would contribute toward the expenses of residence. However, this changed about six months ago. Apparently, a source of disagreement for the parties involved the extent to which wife’s children should be forced to contribute toward household expenses. Husband did not believe that either Esther or wife’s son contributed nearly enough to the expenses of the household. Therefore, he proclaimed on several occasions that he no longer had any interest in contributing toward the household bills.

Husband owns a trailer located in Lawn. Esther lived in this trailer for a time prior to 2008. However, the trailer has been vacant since 2008. Wife stated that husband has [250]*250spent a considerable amount of time “fixing up” the trailer in his spare time. Still, husband claims that the trailer is unlivable because of its poor condition. In support of his claim, husband presented photographs that he claimed were accurate depictions of the current condition of the trailer. However, on cross-examination, wife’s attorney pointed out that the stamp on the back of the photographs revealed that they were developed in 2008.

Based upon the above testimony, wife seeks to exclude husband from residence. Husband testified that he has hopes of salvaging his marriage and wants to remain in residence in order to do just that. Wife’s motion for exclusive possession of residence is now before us for disposition.

II. LEGAL PRINCIPLES

Exclusive possession of a marital residence is a concept that first surfaced in Pennsylvania during the early I980’s. In the case of Laczkowski v. Laczkowski, 496 A.2d 56 (Pa. Super. 1985), the Superior Court ended all debate about whether Courts possess the authority to award possession of a marital home during the pendency of a divorce. Citing the “full equity power and jurisdiction” of courts in matrimonial cases, the Superior Court stated: “we hold that the lower court had the authority to temporarily award the marital residence, pending equitable distribution of marital property, to a spouse having physical custody of a minor child.” Id. at 60.

In 1990, the authority of a court to award exclusive possession of a marital home was codified. 23 Pa.C.S.A. § 3502(c) reads: “The court may award, during the pendency of the action or otherwise, to one or both of the parties [251]*251the right to reside in the marital residence.” Surprisingly, no appellate court precedent has been articulated since Laczkowski and its codification at § 3502(c) of the divorce code. However, quite a few common pleas courts have wrestled with the concept. We will highlight several.

The case of Uhler v. Uhler, 41 Pa. D. & C. 3d 3 (1985), aff'd, 626 A.2d 656 (Pa. Super. 1993), involved a home that was damaged by fire. For six months prior to the fire, Mrs. Uhler resided alone at the marital residence. As the home was being reconstructed, Mr. Uhler voiced a desire to return and live at the newly reconstructed house. The Lancaster County Court of Common Pleas cited “the presence of children in the home and their emotional welfare” as the “most important consideration.”

The court concluded:

The case at bar does not present a situation which would compel the court to enter an award of exclusive possession of the home....
The equitable remedy of exclusive pendente lite possession of the “marital” home is an award which is to be used sparingly. The situation presented by petitioner does not give rise to the protections afforded by the divorce code. 41 Pa. D. & C. 3d at 6-7.

In Vuocolo v. Vuocolo, 42 Pa. D&C 3d 398 (1987), the Lawrence County Court of Common Pleas reached a result different than the one is Uhler, primarily because it focused on the interest of the parties’ 15-year-old son. The court in Vuocolo stated:

[252]

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Laczkowski v. Laczkowski
496 A.2d 56 (Supreme Court of Pennsylvania, 1985)
Merola v. Merola
19 Pa. D. & C.4th 538 (Luzerne County Court of Common Pleas, 1993)
Uhler v. Uhler
41 Pa. D. & C.3d 3 (Lancaster County Court of Common Pleas, 1985)
Duzgun v. Duzgun
76 Pa. D. & C.4th 538 (Monroe County Court of Common Pleas, 2005)
Chappell v. Chappell
81 Pa. D. & C.4th 235 (Lawrence County Court of Common Pleas, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
21 Pa. D. & C.5th 246, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reynolds-v-reynolds-pactcompllebano-2011.