Shanoski v. Miller

CourtSuperior Court of Maine
DecidedFebruary 4, 2001
DocketCUMap-00-065
StatusUnpublished

This text of Shanoski v. Miller (Shanoski v. Miller) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shanoski v. Miller, (Me. Super. Ct. 2001).

Opinion

SOT aE es ae STATE OF MAINE ee TE Ata SUPERIOR COURT CUMBERLAND, ss. ype a iites 23. CIVIL ACTION VOIR UP PEGE DOCKET NO. AP-00-965 REC -Cum- af 206 |

aA

HENRY SHANOSKI,

Appellant v. DECISION ON APPEAL

MARJORIE MILLER,

Appellee

FACT UAL BACKGROUND

Henry Shanoski and Marjorie Miller were married in North Carolina in 1988, where they resided until May, 1994. In 1994, both Marjorie and Henry moved to Maine where their daughter Meredith was born on June 30, 1994. On January 28, 1995, Marjorie and Meredith moved back to North Carolina. Henry then filed a complaint for divorce in Maine on March 16, 1995. On March 31, 1997, the district court entered an order and judgment of divorce incorporating a report of referee dated March 28, 1997 and granting the parties shared parental rights. The report of referee and divorce judgment provided for Meredith to spend six weeks with her father during the summer of 1997, one week in the fall, and ten days at Christmas. The report also provided that another reference would be held in January, 1998 to determine future parent-child contact schedules. On January 30, 1998 Dana Cleaves, the referee, took evidence on the contact schedule and ordered that Henry’s time with his daughter be increased to two weeks in the spring, fall and at Christmas, and six weeks in the summer and also set forth specific dates of contact through August, 2000.

On June 15, 1999, Marjorie filed a complaint in North Carolina seeking to modify the Maine custody order. Henry filed a motion in the Maine District Court to enjoin the North Carolina proceedings and to enforce the Maine order’s mandatory arbitration provision concerning disputes over Meredith’s schedule on July 9, 1999. In an order dated September 1, 1999, Judge Bradley denied Mr. Shanoski’s request to enjoin the North Carolina proceedings but ordered Marjorie to comply with the court-ordered arbitration procedure.

On September 15, 1999, a hearing was held in North Carolina on the jurisdictional issue. Following this hearing, Judge Bradley and Judge Richard Chaney of the District Court of North Carolina corresponded regarding jurisdiction. In a November 24, 1999 letter, Judge Chaney questioned Maine’s jurisdiction. Judge Bradley responded in a letter dated January 13, 2000 that Maine’s continuing jurisdiction was proper. In a February 28, 2000 letter, Judge Chaney concluded that

the case should proceed in North Carolina. He then issued an order on March 20, 2000 denying Mr. Shanoski’s motion to dismiss the North Carolina action and finding that North Carolina had subject matter jurisdiction. That same day, Mr. Shanoski filed a notice of appeal to the North Carolina Court of Appeals.

On April 5, 2000, Mr. Shanoski filed a motion to clarify the dates of contact for Meredith after August, 2000. On April 18, 2000, Ms. Miller filed a motion to decline jurisdiction accompanied by an affidavit agreeing that the parties were obligated to follow the 12-week schedule set by the Maine court. Following a hearing, Judge Bradley issued an order dated June 5, 2000 granting Ms. Miller’s motion. This order

declined to exercise jurisdiction over the matter based on a consideration of the factors set forth in § 1751(2) of the Uniform Child Custody Jurisdiction and Enforcement Act (“UCCJEA”).

The question before the court was “whether Maine, while having jurisdiction, should decline to exercise its jurisdiction on the grounds of inconvenient forum.” The Maine district court found that a substantial change in circumstances existed either because the divorce judgment makes no provision for contact after August 31, 2000 or because Meredith, who was only age four when the divorce was granted, was then attending kindergarten and would be in school full - time as a first grader in the fall. Judge Bradley then identified the issue before the court as “what contact schedule between Meredith and her father meets the child’s best interest,” and found that North Carolina was the more convenient and more appropriate forum to determine that issue. Noting that while Meredith has spent 12 weeks a year in Maine and has attended some school sessions here, the child spent far more time, approximately 80%, in North Carolina. Judge Bradley also noted that care providers, teachers and others have had significant contact with Meredith in that state, as well as a number of witnesses from her school in North Carolina, who would give testimony central to the question presented.

On June 12, 2000, Shanoski filed a motion to reconsider based on his

agreement that Meredith’s 12 weeks of contact in Maine would not occur during her

school schedule in North Carolina.! Mr. Shanoski also filed a motion for additional

1 Mr. Shanoski argues that this agreement mooted the need for any witnesses to testify as to

the extent to which Meredith’s contact schedule would interfere with her school schedule in North Carolina. findings of fact dated June 14, 2000 pursuant to MLR. Civ. P. 52(b). On June 20, 2000, Ms. Miller filed a motion to dismiss Mr. Shanoski’s appeal of the North Carolina jurisdictional order, which the North Carolina Court of Appeals subsequently denied. On July 17, 2000, Judge Bradley incorporated the findings in her January 13, 2000 letter to North Carolina Judge Chaney as findings of fact but did not rule on the motion to reconsider. A hearing on that motion was held on August 16, 2000. The next day, Judge Bradley denied the motion to reconsider. Mr. Shanoski filed an amended notice of appeal to the Superior Court on August 24, 2000, appealing the June 5, 2000 order declining to exercise jurisdiction and the August 17, 2000 order denying his motion for reconsideration. DISCUSSION

I. Applicable Statute

The UCCJEA took effect in Maine on January 1, 2000. 19-A M.RS.A. § 1782 (Supp. 2000). However, a “motion or other request for relief made in a child custody proceeding or to enforce a child custody determination that was commenced before January 1, 2000 is governed by the law in effect at the time the motion or other request was made.” 19-A M.RS.A. § 1783 (Supp. 2000). As the uniform comment notes, although a child custody proceeding will last throughout the minority of the child, the commencement of a proceeding prior to the effective date of the UCCJEA does not necessarily mean that jurisdiction will continue to be governed by prior law. 19-A M.RS.A. § 1783 uniform cmt. If a motion to modify an existing

determination is filed after the enactment of the UCCJEA, the provisions of that act apply. Id. If the motion is filed prior to enactment of the UCCJEA, however, it may be completed under the rules in effect at the time the motion was filed. Id.

Ms. Miller’s argument that the UCCJA is the applicable act is based on Mr. Shanoski’s July, 1999 Motion to Enforce. That motion was resolved in Judge Bradley’s September 1, 1999 order granting Mr. Shanoski’s motion. It was Mr. Shanoski’s April 5, 2000 Motion to Clarify that commenced the proceedings at issue in Maine. The UCCJEA is therefore the applicable statute.

II, Maine’s Exclusive, Continuing Jurisdiction Under the UCCJEA and PKPA

Jurisdictional questions regarding child custody determinations are controlled both by the UCCJEA, 19-A M.R.S.A. §§ 1731-1783 (Supp. 2000), and the Parental Kidnapping Prevention Act (“PKPA”), 28 U.S.C.A. § 1738A (West 1994 & Supp. 2000). In the event of a conflict between the provisions of two statutes, the PKPA

controls. See Barclay v. Eckert, 2000 ME 10, { 8, 743 A.2d 1259, 1262. Because there is

no conflict here, the two statutes should be considered in conjunction with one another. See id.

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

Related

Barclay v. Eckert
2000 ME 10 (Supreme Judicial Court of Maine, 2000)
Sewall v. Saritvanich
1999 ME 46 (Supreme Judicial Court of Maine, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Shanoski v. Miller, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shanoski-v-miller-mesuperct-2001.