Russell Karl Falkenburg v. Elizabeth Sotelo Solano

CourtCourt of Appeals of Kentucky
DecidedFebruary 10, 2022
Docket2020 CA 001597
StatusUnknown

This text of Russell Karl Falkenburg v. Elizabeth Sotelo Solano (Russell Karl Falkenburg v. Elizabeth Sotelo Solano) 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
Russell Karl Falkenburg v. Elizabeth Sotelo Solano, (Ky. Ct. App. 2022).

Opinion

RENDERED: FEBRUARY 11, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-1597-MR

RUSSELL KARL FALKENBURG APPELLANT

APPEAL FROM JESSAMINE CIRCUIT COURT v. HONORABLE JEFF MOSS, JUDGE ACTION NO. 19-CI-00758

ELIZABETH SOTELO SOLANO1 APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, CETRULO, AND JONES, JUDGES.

CALDWELL, JUDGE: Russell Karl Falkenburg appeals from the Jessamine

Family Court’s rulings on several matters in a proceeding in which Falkenburg

initially sought to dissolve, but later sought to annul, his marriage to Elizabeth

Sotelo Solano. We affirm.

1 Falkenburg refers to the appellee in his notice of appeal as Elizabeth Sotelo Solano, consistent with his petition for dissolution of marriage. Although the dissolution decree indicated that the legal name of the respondent in the divorce action was Elizabeth Falkenburg, we will refer to the appellee as Solano based on the notice of appeal. Before addressing the merits of Falkenburg’s arguments, we must

address the effect of Falkenburg’s failure to comply with key briefing requirements

and of Solano’s failure to file an appellee brief.

We Review for Manifest Injustice Due to Lack of Proper Preservation Statement and Lack of Specific Citations to the Record in Appellant’s Brief

Falkenburg’s brief fails to comply with two key requirements for an

appellant’s brief. First, his brief does not comply with the requirement that the

argument portion of an appellant’s brief state if and how issues on appeal were

properly preserved–meaning that the issues were raised to the family court so it

had an opportunity to rule on them. See CR2 76.12(4)(c)(v) (emphasis added)

(requiring that briefs for appellants contain: “An ‘ARGUMENT’ conforming to

the statement of Points and Authorities, with ample supportive references to the

record and citations of authority pertinent to each issue of law and which shall

contain at the beginning of the argument a statement with reference to the

record showing whether the issue was properly preserved for review and, if

so, in what manner.”).

Second, his appellant brief does not comply with the requirement that

the appellant provide ample supporting references to pages of the written record

and to dates and times of audio and/or video recordings wherein the appellant

2 Kentucky Rules of Civil Procedure.

-2- presented such issues to the family court. See CR 76.12(4)(c)(iv) (emphasis

added) (requiring that appellant’s brief contain: “A ‘STATEMENT OF THE

CASE’ consisting of a chronological summary of the facts and procedural events

necessary to an understanding of the issues presented by the appeal, with ample

references to the specific pages of the record, or tape and digital counter

number in the case of untranscribed videotape or audiotape recordings, or date

and time in the case of all other untranscribed electronic recordings, supporting

each of the statements narrated in the summary.”).

When the appellant fails to include a proper preservation statement

and fails to cite to the record in a manner enabling an appellate court to easily find

where the issue was argued to the trial court, Kentucky case law makes clear that

the reviewing appellate court has no obligation to search the record. See, e.g., S.T.

v. Cabinet for Health and Family Services, 585 S.W.3d 769, 777 (Ky. App. 2019);

Koteras v. Commonwealth, 589 S.W.3d 534, 540 (Ky. App. 2018).

Briefs may be stricken for non-compliance with briefing

requirements. CR 76.12(8)(a). And an appellate court may only review for

manifest injustice when an appellant fails to provide a preservation statement with

supporting references to the record. Ford v. Commonwealth, 628 S.W.3d 147, 155

(Ky. 2021) (“the manifest injustice standard of review is reserved only for errors in

appellate briefing related to the statement of preservation. If a party fails to inform

-3- the appellate court of where in the record his issue is preserved, the appellate court

can treat that issue as unpreserved.”). See also CR 61.02 (emphasis added) (“A

palpable error which affects the substantial rights of a party may be considered by

the court on motion for a new trial or by an appellate court on appeal, even though

insufficiently raised or preserved for review, and appropriate relief may be granted

upon a determination that manifest injustice has resulted from the error.”).

Our precedent also makes clear that although pro se litigants are

perhaps not expected to make arguments with the same sophistication as lawyers,

pro se litigants must comply with the briefing requirements in our civil rules and

may suffer consequences for failing to do so. See Koester v. Koester, 569 S.W.3d

412, 415 (Ky. App. 2019) (striking pro se appellant’s brief and dismissing appeal

due to several substantive failures to comply with briefing requirements–especially

after he failed to correct errors in reply brief after being informed of his

noncompliance); Prescott v. Commonwealth, 572 S.W.3d 913, 919 (Ky. App.

2019) (noting that despite some leniency afforded to pro se litigants, pro se

litigants are expected to follow court rules so we limited our review to “those

portions of Prescott’s arguments supported by careful and correct citation to the

record” and declined to fully analyze issues which were raised in brief in a manner

not complying with governing rules).

-4- In the instant case, we elect not to strike Falkenburg’s brief so we do

not summarily dismiss his appeal. However, we review the issues he raises on

appeal only for manifest injustice since he failed to indicate if or how issues were

preserved for appeal with specific references to the record. Furthermore, we may

decline to address certain issues or provide less detailed analysis of some issues

due to his failure to provide specific citations to pages of the written record and/or

dates and times in recorded hearings wherein these issues were discussed in the

family court. See Prescott, 572 S.W.3d at 919.

We Opt Against CR 76.12(8)(c) Sanctions for Failure to File Appellee Brief

Solano failed to file an appellee brief. So, we would have the

authority to take steps such as treating the lack of appellee brief as a confession of

error or simply accepting the appellant’s statement of facts and issues as correct

under CR 76.12(8)(c).3 We also have discretion to not choose to exercise any of

the options listed in CR 76.12(8)(c). Roberts v. Bucci, 218 S.W.3d 395, 396 (Ky.

App. 2007). Under the unique facts and circumstances of this case, including the

issues presented and the deficiencies in Falkenburg’s brief, we choose not to

exercise any of the options listed in CR 76.12(8)(c).

3 CR 76.12(8)(c)(ii) states that we could reverse the family court’s judgment if the appellant’s brief “reasonably appears to sustain such action;” however, we conclude that Falkenburg’s brief does not appear to reasonably support reversing the family court’s judgment as we discuss in further detail elsewhere in this Opinion.

-5- FACTS AND PROCEDURAL HISTORY

Falkenburg and Solano were married in February 2018 in Texas.

They separated in June 2019, following Falkenburg’s return to Texas after a

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

Related

Kenney v. Hanger Prosthetics & Orthotics, Inc.
269 S.W.3d 866 (Court of Appeals of Kentucky, 2007)
Roberts v. Bucci
218 S.W.3d 395 (Court of Appeals of Kentucky, 2007)
Stopher v. Commonwealth
57 S.W.3d 787 (Kentucky Supreme Court, 2001)
Parks v. Parks
418 S.W.2d 726 (Court of Appeals of Kentucky (pre-1976), 1967)
Eck v. Eck
793 S.W.2d 858 (Court of Appeals of Kentucky, 1990)
Koester v. Koester
569 S.W.3d 412 (Court of Appeals of Kentucky, 2019)
Prescott v. Commonwealth
572 S.W.3d 913 (Court of Appeals of Kentucky, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Russell Karl Falkenburg v. Elizabeth Sotelo Solano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/russell-karl-falkenburg-v-elizabeth-sotelo-solano-kyctapp-2022.