Shockey v. Shockey

30 Va. Cir. 493, 1979 Va. Cir. LEXIS 64
CourtFrederick County Circuit Court
DecidedApril 3, 1979
DocketCase No. (Chancery) 5909
StatusPublished

This text of 30 Va. Cir. 493 (Shockey v. Shockey) is published on Counsel Stack Legal Research, covering Frederick County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shockey v. Shockey, 30 Va. Cir. 493, 1979 Va. Cir. LEXIS 64 (Va. Super. Ct. 1979).

Opinion

By Judge Robert K. Woltz

This is my letter opinion making determination of the principal issue between the parties to this divorce suit, namely, custody of the two minor children of the marriage, a girl now aged five and one-half and a boy three and one-half.

The evidence was voluminous having been heard ore tenus for all or a portion of six days over a period in excess of three months. Having done considerably more research than in the ordinary case of this type, it was my original intention to write at some length a formal opinion; but in the interest of both parents and perhaps even more so the children themselves, that plan has been abandoned in order to save further delay and bring this matter to a determination.

It is my judgment that the custody of the two children, Hilary T. Shockey and James D. Shockey, III, should be awarded to the complainant, James D. Shockey, Jr. The bases for this judgment are as follows:

The harsh and inflexible common law rule in matters of child custody gave the father, as a matter of absolute right as against all the world, custody of his legitimate infant children, even to exclusion of the mother from any access to them, Latham v. Latham, 71 Va. (30 Gratt.) 307, 331 (1878). This exalted paternal rights to the exclusion or denial of maternal and filial rights. This principle has been greatly modified both by the case law and statute.

[494]*494The most basic principle in child custody cases is stated in Mullen v. Mullen, 188 Va. 259, 269 (1948): 44[T]he welfare of the infant is the primary, paramount, and controlling consideration of the court in all controversies between parents over the custody of their minor children. All other matters are subordinate.” In support of the proposition, cases as early as 1898 were cited, and the earliest itself cited another several years older. Even the oldest reported case in Virginia concerning the element of custody in a divorce setting, decided in 1872, when the shadow of the overhang of the common law rule was still felt, in reaching its decision mentions “having in view the good of the child.” Carr v. Carr, 63 Va. (22 Gratt.) 168, 174 (1872). Virtually all if not all cases in our Reports since Mullen recognized this principle, sometimes stating it in almost the same language as Mullen.

The statutory incursion on the common law is to precisely the same effect. Section 31-15 provides that where parents are separated, whether divorced or not, the court “in awarding the custody of the child to either parent or to some other person shall give primary consideration to the welfare of the child . . .” this provision having been added to the statute in 1930. The second principle is corollary to the first. While as much consideration as possible should be given to the “tender ties of affection” of parents, the rights of neither parent are superior to the rights of the child, Mullen, supra, and though the rights of the parents are to be respected, the child’s welfare is “regarded more highly than the technical legal rights of the parents.” Forbes v. Haney, 204 Va. 712 (1963).

The third major principle is expressed statutorily in § 31-15 also, providing that “as between the parents, there shall be no presumption of law in favor of either.” Mullen takes note of this statutory change, at page 269, as does the most recently reported custody case, McCreery v. McCreery, 218 Va. 352, 357 (1977).

A fourth principle, stated in Mullen at pages 270 and 271, should be noted as it has had a strong influence in custody cases: “It is now generally recognized that the mother is the natural custodian of her child of tender years, and that if she is a fit and proper person, other things being equal, she should be given the custody in order that the child may receive the attention, care, supervision, and kindly advice, which arise from a mother’s love and devotion, for which no substitute has ever been found.” (The dissent, four to two in that case, at page 278 asserts the rule had been “that the innocent party upon whose [495]*495prayer the divorce is granted, other things being equal, usually will be given the custody of the children.”) This principle that the mother is natural guardian of children of tender years was given important recognition in a number of later cases, e.g., Brooks v. Brooks, 200 Va. 530 (1959); Forbes v. Haney, supra; Moore v. Moore, 212 Va. 153 (1971).

Commencing with White v. White, 215 Va. 765 (1975), some controversy developed over the true import of the “rule” that the mother was the natural custodian of children of tender years, the dissent in that case viewing the majority opinion as a departure from Mullen. That dissent has continued in three more cases, Burnside v. Burnside, 216 Va. 691 (1976), Clark v. Clark, 217 Va. 924 (1977), and the most recent on the subject, McCreery, supra.

The “tender years” principle as enunciated in Mullen contains two important internal, limiting qualifications: the mother is to be a “fit and proper person,” and “other things” are to be “equal.” The cases which peipetuate the principle of mother as natural custodian such as Moore, supra, never failed to state these two limiting qualifications, and Portwig v. Ryder, 208 Va. 791 (1968), points out that the rule is a flexible one “not to be applied without regard to surrounding circumstances.” Harper v. Harper, 217 Va. 477 (1976), points out that the Mullen-Moore “rule” is “not a rule of law,” but “no more than a permissible and rebuttable inference.” McCreery states that confusion concerning the “tender years presumption” has arisen due to confusing “the right of a parent to custody of its minor child” with “the right of a child to the custodian care of a parent” and emphasizes that the principle does not relate to the rights of the two parents, but the right of the child and service of the child’s best interest.

Whatever else may be said of the cases, from the latest, McCreery, back at least as far as Mullen, all the cases found themselves on the principle that in determining custody, the welfare of the children involved is preeminent above all other considerations. It is upon this prime rule as applied to the evidence in this case that judgment is based.

I further find the mother not to be unfit, but that “other things” are not equal, and that the complainant father’s evidence rebuts the “permissible inference” of the “tender years” principle establishing him as the preferred parent from the standpoint of serving the children’s best interests.

[496]*496None of the cases cited above goes into the question of the degree of or the differences in the fitness of a child’s parents. It is enough that a parent, whether mother or father, be fit, but differences in their degree of fitness can well be construed as one of the “other things” which may deny application of the inference of a mother’s superiority to be custodian of a child tender in years.

Viewing the evidence, the father has far greater economic capabilities than the mother, he being well-to-do or even wealthy.

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Related

McCreery v. McCreery
237 S.E.2d 167 (Supreme Court of Virginia, 1977)
Brown v. Brown
237 S.E.2d 89 (Supreme Court of Virginia, 1977)
Clark v. Clark
234 S.E.2d 266 (Supreme Court of Virginia, 1977)
Brooks v. Brooks
106 S.E.2d 611 (Supreme Court of Virginia, 1959)
Portewig v. Ryder
160 S.E.2d 789 (Supreme Court of Virginia, 1968)
Moore v. Moore
183 S.E.2d 172 (Supreme Court of Virginia, 1971)
Forbes v. Haney
133 S.E.2d 533 (Supreme Court of Virginia, 1963)
Burnside v. Burnside
222 S.E.2d 529 (Supreme Court of Virginia, 1976)
White v. White
213 S.E.2d 766 (Supreme Court of Virginia, 1975)
Harper v. Harper
229 S.E.2d 875 (Supreme Court of Virginia, 1976)
Mullen v. Mullen
49 S.E.2d 349 (Supreme Court of Virginia, 1948)

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Bluebook (online)
30 Va. Cir. 493, 1979 Va. Cir. LEXIS 64, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shockey-v-shockey-vaccfrederick-1979.