Sekou Wiggs, Sr. v. Tamikya St. Clair

CourtCourt of Appeals of Washington
DecidedJuly 27, 2020
Docket80003-5
StatusUnpublished

This text of Sekou Wiggs, Sr. v. Tamikya St. Clair (Sekou Wiggs, Sr. v. Tamikya St. Clair) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sekou Wiggs, Sr. v. Tamikya St. Clair, (Wash. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

SEKOU WIGGS SR., No. 80003-5-I Appellant, DIVISION ONE v. UNPUBLISHED OPINION TAMIKYA ST. CLAIR,

Respondent.

DWYER, J. — Sekou Wiggs Sr. appeals from the superior court’s order

revising a commissioner’s order denying Tamikya St. Clair’s petition to modify an

order of child support. He asserts that the superior court erred in finding that St.

Clair met the statutory predicates for modifications. He further asserts that the

judge erred by imputing income to him, ordering postsecondary education

support, and awarding attorney fees and costs to St. Clair. Because the trial

court failed to enter findings of fact and conclusions of law to support its fee

award, we remand for further proceedings on that request for relief. We

otherwise affirm.

I

Sekou Wiggs Sr. and Tamikya St. Clair were involved in a lengthy intimate

relationship but they never married. At the time the superior court entered the

order at issue in this appeal, the children were 25, 19, and 8 years old. Wiggs is No. 80003-5-I/2

also the father of a minor child with Phala Sir. Wiggs has worked as a real estate

agent and St. Clair is a teacher for the Seattle School District.

In March 2013, Wiggs filed a petition to dissolve the committed intimate

relationship with St. Clair. Final agreed orders and a decree of dissolution were

entered on July 18, 2014. The final order of child support required Wiggs to

make monthly $500 child support payments to St. Clair based on Wiggs’s

monthly net income of $2,311.1 This amount represented a downward deviation

from the standard child support calculation of $567 because of Wiggs’s

responsibility to support his other minor child with Sir. The order also required

Wiggs to pay support until the children reach age 18 or graduate from high

school, whichever is later. The order reserved the matter of postsecondary

education support.

On April 23, 2015, Wiggs filed a petition for modification of child support,

claiming that he had lost his job as an apartment manager. That petition was

dismissed based on a procedural error. On July 24, 2015, Wiggs filed another

petition for modification. On November 13, 2015, after a trial by affidavit, the

superior court entered an order denying and dismissing Wiggs’s petition, finding

that he failed to satisfy his burden under RCW 26.09.170 to prove a significant

change in circumstances. The court found that the existing child support order

was predicated on Wiggs earning approximately $15 per hour and that any

subsequent modification would support imputation of income at the same level.

1 At that time, the parties’ middle child was age 14 and the youngest was age 8.

2 No. 80003-5-I/3

The court further found that Wiggs had not shown any “medical, psychological, or

physical reasons why he is unable to work.”

On September 1, 2016, Wiggs filed a petition to vacate the July 2014

decree. The parties resolved the dispute by agreement, and the court entered

amended orders on September 21, 2017. The agreed amended child support

order was in most respects unchanged from the 2014 order. The order still

identified Wiggs’s actual monthly income to be $2,311, required him to pay $500

per month to support the two minor children, required support to be paid until the

children turn 18 or complete high school, and reserved the issue of

postsecondary support.

On May 24, 2018, St. Clair filed a pro se petition to modify child support.

Referring to the original 2014 child support order, St. Clair alleged that the court

should modify the child support amount because the current order was signed at

least two full years previously and the parents’ income had changed. She further

alleged that there had been a substantial change in circumstances since the

current order was signed. Specifically, St. Clair alleged that her financial

situation had worsened, that Wiggs was earning unreported income, and that

their eldest daughter’s needs had changed because she would still be in high

school past age 18 and was preparing to enter college in September 2018.

In a declaration in support of her petition, St. Clair asserted that Wiggs

had been concealing income to avoid his child support obligations. She

presented evidence that Wiggs had a significant presence in the community as a

successful real estate agent. St. Clair alleged that Wiggs was funneling his real

3 No. 80003-5-I/4

estate commissions through Sir, who had become a real estate agent and joined

Wiggs’s real estate team. On this basis, St. Clair asked the court to impute

income to Wiggs.

Wiggs admitted that he was working as a real estate agent and earning

income on a commission basis. But he asserted that he was existing day to day

on a very limited income, relying substantially on public assistance, and living in

a small rented room with his minor child from his relationship with Sir. Wiggs

also claimed that he suffers from depression, anxiety, and severe uncontrolled

hypertension.

In response, St. Clair submitted another declaration, which called to

attention issues regarding Wiggs’s credibility. Wiggs responded by defending his

credibility and continuing to assert that he is destitute. Sir filed a declaration

asserting that Wiggs is struggling financially and that she sometimes allows him

to assist her with real estate transactions.

On December 21, 2018, following a hearing, a commissioner denied St.

Clair’s petition. The commissioner found that, at the time of St. Clair’s petition,

two years had not passed since the September 21, 2017 child support order was

issued and that St. Clair had not pled that the prior order worked a severe

economic hardship. The commissioner, citing Wiggs’s receipt of food stamp

benefits, further found that Wiggs had no ability to pay postsecondary support

and that he was not voluntarily unemployed.

On December 31, 2018, St. Clair filed motions to revise and reconsider

the commissioner’s ruling regarding modification of child support. In the revision

4 No. 80003-5-I/5

motion, St. Clair asserted that the agreed 2017 child support order was not a

modification of the original 2014 child support order.

On revision, the superior court granted St. Clair’s petition, modified the

child support amount based on imputed income, and ordered postsecondary

support. The judge found that St. Clair sufficiently pleaded the requirements for

modification under RCW 26.09.170(6) due to “severe economic hardship” and

because there was a child in high school after age 18. The court similarly found

that St. Clair met the requirements for modification under RCW 26.19.090 based

on the need for postsecondary support on the older child’s entrance into college.

Having found that St. Clair met the statutory predicates for modification,

the judge further found that St. Clair provided sufficient evidence that Wiggs was

voluntarily unemployed or underemployed. The judge rejected Wiggs’s account

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

Related

In Re the Marriage of Shellenberger
906 P.2d 968 (Court of Appeals of Washington, 1995)
Schumacher v. Watson
997 P.2d 399 (Court of Appeals of Washington, 2000)
In Re the Welfare of McGee
679 P.2d 933 (Court of Appeals of Washington, 1984)
Mahler v. Szucs
957 P.2d 632 (Washington Supreme Court, 1998)
In Re Marriage of Moody
976 P.2d 1240 (Washington Supreme Court, 1999)
In the Matter of Marriage of Tang
789 P.2d 118 (Court of Appeals of Washington, 1990)
Olson v. City of Bellevue
968 P.2d 894 (Court of Appeals of Washington, 1998)
In Re the Welfare of Smith
505 P.2d 1295 (Court of Appeals of Washington, 1973)
Grey v. Leach
244 P.3d 970 (Court of Appeals of Washington, 2010)
Truck Ins. Exchange v. VanPort Homes, Inc.
58 P.3d 276 (Washington Supreme Court, 2002)
State v. Townsend
15 P.3d 145 (Washington Supreme Court, 2001)
In Re Marriage of Bobbitt
144 P.3d 306 (Court of Appeals of Washington, 2006)
In Re Marriage of Fiorito
50 P.3d 298 (Court of Appeals of Washington, 2002)
In Re Marriage of Dodd
86 P.3d 801 (Court of Appeals of Washington, 2004)
Hartford Ins. Co. v. Ohio Cas. Ins. Co.
189 P.3d 195 (Court of Appeals of Washington, 2008)
In Re Goude
219 P.3d 717 (Court of Appeals of Washington, 2009)
Burrill v. Burrill
56 P.3d 993 (Court of Appeals of Washington, 2002)
State v. Lown
66 P.3d 660 (Court of Appeals of Washington, 2003)
Mahler v. Szucs
135 Wash. 2d 398 (Washington Supreme Court, 1998)
In re the Marriage of Moody
976 P.2d 1240 (Washington Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Sekou Wiggs, Sr. v. Tamikya St. Clair, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sekou-wiggs-sr-v-tamikya-st-clair-washctapp-2020.