Sarah Lee (Now Whiting) v. Aaron Childs

2020 Ark. App. 156, 597 S.W.3d 124
CourtCourt of Appeals of Arkansas
DecidedMarch 4, 2020
StatusPublished
Cited by1 cases

This text of 2020 Ark. App. 156 (Sarah Lee (Now Whiting) v. Aaron Childs) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sarah Lee (Now Whiting) v. Aaron Childs, 2020 Ark. App. 156, 597 S.W.3d 124 (Ark. Ct. App. 2020).

Opinion

Reason: I attest to the Cite as 2020 Ark. App. 156 accuracy and integrity of this document ARKANSAS COURT OF APPEALS Date: 2021-06-21 14:14:02 Foxit PhantomPDF Version: 9.7.5 DIVISION III No. CV-19-288

Opinion Delivered March 4, 2020 SARAH LEE (NOW WHITING) APPEAL FROM THE LONOKE APPELLANT COUNTY CIRCUIT COURT [NO. 43DR-08-873] V. HONORABLE JASON ASHLEY AARON CHILDS PARKER, JUDGE

APPELLEE AFFIRMED

N. MARK KLAPPENBACH, Judge

Appellant Sarah Whiting appeals the circuit court’s January 2019 order that awarded

Sarah and appellee Aaron Childs joint physical custody of their ten-year-old daughter AMC.

Previously, the parents shared joint legal custody, and Sarah had primary physical custody;

Aaron had visitation privileges. Sarah argues that the circuit court clearly erred (1) in finding

that there were material changes in circumstances, and (2) in concluding that AMC’s best

interest was served by changing to joint physical custody, expanding Aaron’s time with

AMC. We affirm.

The law on this subject is well settled. A judicial award of custody will not be

modified unless it is shown that there are changed conditions demonstrating that a

modification of the decree will be in the best interest of the child, or when there is a showing

of facts affecting the best interest of the child that were either not presented to, or not

known by, the circuit court when the original custody order was entered. Case v. Van Pelt, 2019 Ark. App. 382, 587 S.W.3d 567. Generally, to promote stability and continuity in

the life of the child and to discourage repeated litigation of issues that have already been

decided, courts impose more stringent standards for modifications in custody than they do

for initial determinations of custody. Id. The party seeking modification has the burden of

showing a material change in circumstances. Id. This court performs a de novo review of

child-custody matters, but we will not reverse a circuit court’s findings unless they are clearly

erroneous. Id. A finding is clearly erroneous when, although there is evidence to support

it, the reviewing court is left with the definite and firm conviction that a mistake has been

made. Id. Because the question whether the circuit court’s findings are clearly erroneous

turns largely on the credibility of the witnesses, we give special deference to the superior

position of the circuit court to evaluate the witnesses, their testimony, and the child’s best

interest. Id. There are no cases in which the superior position, ability, and opportunity of

the circuit court to observe the parties carry as great a weight as those involving minor

children. Id.

With these rules in mind, we turn to the facts and evidence of this case. AMC was

born in August 2008 to unmarried parents. Aaron filed a petition to establish his paternity

in October 2008. By a June 2009 order, Sarah was awarded primary physical custody, and

they shared joint legal custody, although Sarah had final decision-making authority. The

order established Aaron’s child-support obligation. Aaron was awarded standard visitation

that included overnight visitation each Wednesday, alternating weekends from Friday

evening to Sunday evening, two weeks of summer visitation, and specified holiday

visitation.

2 By 2012, the parties fell into discord, resulting in an August 2013 order that

admonished both parents to change their behavior and cooperate in the best interest of their

four-year-old daughter. Aaron had married. This order clarified that any responsible

member of either parent’s family had permission to vacation out of state with the child and

to pick up or drop off the child as routinely necessary. Travel, however, was not to interfere

with the other parent’s court-ordered time unless agreed to in writing. Each party was

permitted one call per day to AMC when she was in the other parent’s custody, from 7:00

p.m. to 8:00 p.m. In 2016, Aaron, his wife Holly, and their children moved from Benton

to Cabot. Sarah and AMC lived in Cabot.

In July 2017, Aaron filed a motion seeking to change custody. Aaron sought full

custody or, in the alternative, joint physical custody. Aaron alleged material changes and

contended that it was in AMC’s best interest to grant his motion, including that

1. Sarah had initially been supportive of his move to Cabot and expressed willingness for AMC to have more time with Aaron and his family;

2. Sarah instead disallowed any additional time and frustrated his attempts to see AMC;

3. After his move, Sarah indicated that she might marry her boyfriend and move with the child to Fayetteville, all in order to create distance between him and his daughter;

4. Sarah refused to allow him and his family to care for AMC when Sarah was working, choosing instead to leave AMC with her boyfriend or her boyfriend’s mother;

5. Sarah allowed AMC to travel to Memphis with her boyfriend’s mother but did not inform him;

6. Sarah refused to co-parent with him, going so far as to block his calls/texts and then demand he communicate by calls/texts, and did not allow him phone contact

3 during the 7:00 p.m. to 8:00 p.m. window but insisted that she be allowed to call AMC at all hours;

7. Sarah was neglectful of AMC’s health, refusing to abide by doctor’s suggestions or to promote a healthy lifestyle for AMC; and

8. Sarah was volatile, hateful, punitive, and vindictive toward him regarding his contact with AMC “when it suits her mood.”

Aaron contended that Sarah was in violation of the very specific communication and

visitation rules established by the circuit court, warranting that she be held in contempt.

In Sarah’s response, she contended that it was Aaron whose cooperation had declined

and whose behavior was difficult. She denied that she had any intent of moving to

Fayetteville, and she noted that there was not a “right of first refusal” provision concerning

AMC’s care. Sarah stated that she was communicative and informative with Aaron, denying

any claim to the contrary. Sarah described the trip to Memphis as a last-minute day trip to

the zoo, which was a treat from her future mother-in-law to AMC, AMC’s future stepsister,

and another child. She believed this allegation was just Aaron’s effort to harass and control

her. Sarah admitted to having stated that, out of frustration with Aaron’s uncooperative

behavior, no one would tell her when she could call her child, but she denied it was out of

disrespect for or disregard of the court’s authority. She denied neglecting AMC’s medical

needs in any way and instead accused Aaron of letting his wife diagnose AMC. She agreed

that vindictive behavior between parents was detrimental to the child, but she denied any

such behavior. Sarah asked that Aaron’s petition be denied and dismissed. Sarah petitioned

for an increase in child support and for the daily 7:00 to 8:00 p.m. telephone-visitation

provision to be lifted because it was too confining.

4 In November 2017, Aaron requested the appointment of an attorney ad litem for

AMC, which was granted. Sarah requested drug testing, which was ordered. Sarah married

her boyfriend Trey in January 2018, gaining two stepchildren.

In August 2018, Aaron filed an amended petition for a change of custody and to hold

Sarah in contempt. The amended petition added that AMC had exhibited extreme anxiety

caused by Sarah’s hostility toward him. Aaron accused Sarah of several misdeeds, including

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2020 Ark. App. 156, 597 S.W.3d 124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sarah-lee-now-whiting-v-aaron-childs-arkctapp-2020.