Sidney Fyffe v. Lamar Scott Cain

CourtCourt of Appeals of Georgia
DecidedOctober 30, 2019
DocketA19A1162
StatusPublished

This text of Sidney Fyffe v. Lamar Scott Cain (Sidney Fyffe v. Lamar Scott Cain) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sidney Fyffe v. Lamar Scott Cain, (Ga. Ct. App. 2019).

Opinion

FIFTH DIVISION MCFADDEN, C. J., MCMILLIAN, P. J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

October 30, 2019

In the Court of Appeals of Georgia A19A1162. FYFFE v. CAIN et al.

MCMILLIAN, Presiding Judge.

After ten-year-old H. C.’s father (“Father”) was tragically killed in a

motorcycle accident, her mother Sidney Fyffe (“Mother”) took custody of the child,

but fourteen months later, the trial court granted a petition filed by the paternal

grandparents, Scott and Sherree Cain (“Grandparents”), for custody of H. C. The

mother appeals the trial court’s order, and because we find that the evidence, even

when viewed under the appropriate standard, does not support the trial court’s

conclusion that the Mother’s continued custody of H. C. would cause significant,

long-term emotional harm to the child, we reverse.

H. C., who was 11 years old at the time the trial court issued its custody order,

was born to the Mother and Father in 2007. The couple married in 2009 and divorced in 2012. In the divorce decree, the trial court awarded legal custody of H. C. to both

parents and gave physical custody of H. C. to the Father. The Mother was given

visitation rights and ordered to pay child support. On July 29, 2017, the Father was

killed in a motorcycle accident. Following the father’s death, the Mother took H. C.

to live with her, and on August 25, 2017, the Grandparents filed a complaint seeking

physical and legal custody of H. C. The trial court appointed a guardian ad litem to

represent H. C.’s interests in the proceedings. Following a hearing, the trial court

awarded legal and physical custody of H. C. to the Grandparents and visitation to the

Mother, entering an order prepared by the Grandparents’ counsel at the trial court’s

direction. The Mother filed the instant appeal, asserting in a single enumeration of

error, that the trial court erred in awarding custody to the Grandparents because they

failed to rebut the presumption under OCGA § 19-7-1 (b.1) in favor of the Mother by

clear and convincing evidence.

1. The start of any analysis that affects parental rights is the recognition that a

parent has “a constitutional right under the United States and Georgia Constitutions

to the care and custody of their children[]” and that this right “is a fiercely guarded

right that should be infringed upon only under the most compelling circumstances.”

(Citation and punctuation omitted.) Clark v. Wade, 273 Ga. 587, 596 (IV) (544 SE2d

2 99) (2001) (plurality opinion). See also In the Interest of K. M., 344 Ga. App. 838,

844 (1) (811SE2d 505 (2018). To guard that right, a non-parent seeking custody must

overcome three constitutionally based presumptions in favor of parental custody: “(1)

the parent is a fit person entitled to custody, (2) a fit parent acts in the best interest of

his or her child, and (3) the child’s best interest is to be in the custody of a parent.”

(Citation and punctuation omitted.) Jewell v. McGinnis, 346 Ga. App. 733, 736 (1)

(816 SE2d 683) (2018).

In custody disputes between a parent and close third-party relatives such as

grandparents, OCGA § 19-7-1 (b.1) provides that the “sole issue for determination

. . . shall be what is in the best interest of the child or children.” However, in order to

protect the parent’s constitutional rights and to overcome the constitutionally based

presumptions, our courts have held that the non-parent under these circumstances

“must show, with clear and convincing evidence,1 that the child will suffer either

physical harm or significant, long-term emotional harm if custody is awarded to the

parent.” Strickland v. Strickland, 298 Ga. 630, 631 (1) (783 SE2d 606) (2016). To

1 “[U]nder Georgia law, the standard of clear and convincing evidence is an intermediate standard of proof which is greater than the preponderance of the evidence standard ordinarily employed in civil proceedings, but less than the reasonable doubt standard applicable in criminal proceedings.” (Citation and punctuation omitted.) Jewell, 346 Ga. App. at 736 (1).

3 assess harm, “trial courts must consider a variety of factors beyond biological

connection or generalized notions of parental fitness,” including

(1) who are the past and present caretakers of the child or children; (2) with whom has the child or children formed psychological bonds and how strong are these bonds; (3) have the competing parties evidenced interest in, and contact with, the child or children over time; and (4) are there any unique medical or psychological needs of the child or children.

Id. Moreover, harm in this context does not include “merely social or economic

disadvantages.” Brawner v. Miller, 334 Ga. App. 214, 216 (1) (778 SE2d 839)

(2015). Suffice it to say, a non-parent bears a heavy burden in seeking to take custody

of a child away from a parent.

Nevertheless, [i]n reviewing a trial court’s findings in a custody dispute

governed by OCGA § 19-7-1 (b.1), “[i]n the appellate review of a bench trial, a trial

court’s factual findings must not be set aside unless they are clearly erroneous.”

Strickland, 298 Ga. at 633 (1). Moreover, “due deference must be given to the trial

court, acknowledging that it has the opportunity to judge the credibility of the

witnesses, and the evidence must be construed in the light most favorable to the trial

court’s decision.” (Citation and punctuation omitted.) Holdaway v. Holdaway, 338

Ga. App. 477, 483 (789 SE2d 817) (2016).

4 2. With these standards in mind, we turn to the trial court’s findings of fact to

assess the court’s conclusion that significant, long-term emotional harm2 would result

from allowing the Mother to continue with custody and that it is in the best interests

of H. C. for her Grandparents to be awarded permanent physical custody.

(a) H. C.’s Care While in her Mother’s Custody

The trial court acknowledged that in the fourteen months that H. C. was in her

Mother’s custody, her grades were “quite good” and remained at the same level as

when her Father was alive. However, the trial court found that the Mother had used

the “F” word in front of H. C. and on social media and that she had called the

Grandparents profane names.3 Twice, H. C. had been put “on restriction” and had her

cell phone taken away from her as discipline. Also, the Mother limited visitation with

the Grandparents, and on one occasion it was because H. C. was “on restriction.” The

Mother also received a speeding ticket while H. C. was in the car.

2 The trial court did not conclude that H. C. would suffer any physical harm by continuing to live with the Mother, but noted in several findings of fact the jobs that the Mother has held over time, that she is now receiving $2000 per month from the Social Security Administration, and that she has had several residences since her divorce. 3 The trial court made no finding that H. C. actually heard this name-calling, while noting that the Grandmother believed that H. C.

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Related

Clark v. Wade
544 S.E.2d 99 (Supreme Court of Georgia, 2001)
Brandenburg v. Brandenburg
551 S.E.2d 721 (Supreme Court of Georgia, 2001)
Arnold v. Arnold
566 S.E.2d 679 (Supreme Court of Georgia, 2002)
Brawner v. Miller
778 S.E.2d 839 (Court of Appeals of Georgia, 2015)
Strickland v. Strickland
783 S.E.2d 606 (Supreme Court of Georgia, 2016)
Brannon v. State
783 S.E.2d 642 (Supreme Court of Georgia, 2016)
Holdaway v. Holdaway
789 S.E.2d 817 (Court of Appeals of Georgia, 2016)
JEWELL v. MCGINNIS Et Al.
816 S.E.2d 683 (Court of Appeals of Georgia, 2018)
In re Interest of I.L.M.
816 S.E.2d 620 (Supreme Court of Georgia, 2018)
Mauldin v. Mauldin
745 S.E.2d 754 (Court of Appeals of Georgia, 2013)
Floyd v. Gibson
788 S.E.2d 84 (Court of Appeals of Georgia, 2016)

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