Thomas C. Wooten v. Ashley L. Simmons Wooten

CourtCourt of Appeals of Mississippi
DecidedJanuary 18, 2022
Docket2020-CA-00353-COA
StatusPublished

This text of Thomas C. Wooten v. Ashley L. Simmons Wooten (Thomas C. Wooten v. Ashley L. Simmons Wooten) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas C. Wooten v. Ashley L. Simmons Wooten, (Mich. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CA-00353-COA

THOMAS C. WOOTEN APPELLANT

v.

ASHLEY L. SIMMONS WOOTEN APPELLEE

DATE OF JUDGMENT: 02/04/2020 TRIAL JUDGE: HON. PAULA DRUNGOLE-ELLIS COURT FROM WHICH APPEALED: CLAY COUNTY CHANCERY COURT ATTORNEY FOR APPELLANT: RICHARD SHANE McLAUGHLIN ATTORNEYS FOR APPELLEE: MATTHEW DANIEL WILSON AMANDA SUSAN BEARD NATURE OF THE CASE: CIVIL - DOMESTIC RELATIONS DISPOSITION: AFFIRMED IN PART; REVERSED AND REMANDED IN PART - 01/18/2022 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE CARLTON, P.J., GREENLEE AND SMITH, JJ.

GREENLEE, J., FOR THE COURT:

¶1. The Clay County Chancery Court granted Thomas and Ashley Wooten a divorce

based on the ground of irreconcilable differences. The chancellor also distributed the marital

property, granted sole physical custody of the minor children to Ashley, and granted joint

legal custody of the children to both parties.

¶2. Thomas now appeals from the chancellor’s judgment, arguing that the chancellor

erred by (1) disregarding Ashley’s retirement savings in the equitable-distribution analysis;

(2) granting physical custody of the children to Ashley; and (3) refusing to deviate from the

statutory child-support guidelines. Finding error with only the portion of the chancellor’s judgment regarding Ashley’s retirement savings account, we reverse and remand the case for

further proceedings consistent with this opinion. As to the matter of child custody and child

support, we affirm.

FACTUAL AND PROCEDURAL HISTORY

¶3. Thomas and Ashley Wooten were married on June 18, 2011. They had two children,

B.W. and C.W., before they separated in October 2015.1 On March 19, 2018, Thomas filed

for divorce from Ashley on the statutory ground of desertion and/or habitual cruel and

inhuman treatment or, alternatively, on the ground of irreconcilable differences. On

September 14, 2018, Ashley filed her answer and counter-complaint for divorce. She alleged

that she was entitled to a divorce on the ground of uncondoned adultery and/or habitual cruel

and inhuman treatment. Alternatively, Ashley requested a divorce on the ground of

irreconcilable differences.

¶4. In October 2019, the parties agreed and entered a consent to divorce on the ground of

irreconcilable differences. Before the commencement of trial, the parties agreed that they

would leave the issues of child custody, child support, and property division to the court’s

determination.2 The two-day trial began on October 29, 2019, and concluded on January 15,

2020. Both Thomas and Ashley introduced evidence and presented several witnesses.

¶5. The chancellor issued an order on January 31, 2020, and a supplemental opinion and

final judgment on February 4, 2020. The chancellor awarded Ashley sole physical custody

1 We use initials to protect the identities of the minor children. 2 The parties agreed that the line of demarcation date for the equitable distribution was October 14, 2015.

2 of the children and joint legal custody to both parties. The chancellor ordered that Thomas’

monthly child-support payments be increased from $239 for one child to $780 for two

children. The chancellor also awarded Ashley a retroactive increase in the child support

payments and declined Thomas’ request to reduce the statutory support.3

¶6. As to the property division, the chancellor determined that the parties’ marital property

included (1) two vehicles— a 2000 Ford F250 and a 2015 Dodge Ram; (2) any of Ashley’s

retirement funds accumulated with BancorpSouth Bank from July 2011 to October 14, 2015;

(3) BancorpSouth Bank credit-card debt in the amount of $880; and (4) Discover credit-card

debt in the amount of $1,938.15. According to the chancellor’s findings, the parties’ separate

property consisted of (1) Thomas’ checking and retirement accounts with Kinder Morgan

Gas Company; (2) Ashley’s BancorpSouth Loan; (3) Ashley’s PERS and Cadence Bank

retirement account; and (4) Ashley’s student loan.

¶7. Thereafter, the chancellor awarded Ashley the 2015 Dodge Ram, the BancorpSouth

Bank credit-card debt, and the Discover credit-card debt. Thomas was awarded the 2000 Ford

F250. Subsequently, the chancellor denied Ashley’s request for reimbursement of the

children’s medical expenses and denied her request for attorney’s fees after determining that

Ashley failed to show a financial inability to pay.

¶8. Thomas now appeals from the chancellor’s judgment, arguing that the chancellor

erred by (1) disregarding Ashley’s retirement savings in the equitable-distribution analysis;

3 Thomas and Ashley previously separated in 2009. During the separation, Ashley went to the Department of Human Services seeking child support assistance from Thomas. Thomas agreed to pay child support in the amount of $239 a month for B.W.

3 (2) granting physical custody of the children to Ashley; and (3) refusing to deviate from the

statutory child-support guidelines.

STANDARD OF REVIEW

¶9. “This Court has a limited standard of review in examining and considering the

decisions of a chancellor.” Ravenstein v. Ravenstein, 167 So. 3d 210, 215 (¶8) (Miss. 2014).

If supported by substantial evidence, a chancellor’s factual findings will not be disturbed

unless “the chancellor abused [her] discretion, was manifestly wrong, clearly erroneous, or

applied an erroneous legal standard.” Varnell v. Rogers, 198 So. 3d 1278, 1280 (¶7) (Miss.

Ct. App. 2016). On appeal, this Court “is required to respect the findings of fact made by a

chancellor supported by credible evidence and not manifestly wrong.” Newsom v. Newsom,

557 So. 2d 511, 514 (Miss. 1990). “This is particularly true in the areas of divorce and child

support.” Ferguson v. Ferguson, 639 So. 2d 921, 930 (Miss. 1994) (citing Nichols v. Tedder,

547 So. 2d 766, 781 (Miss. 1989)).

DISCUSSION

I. Equitable Distribution

¶10. Our supreme court has “long recognized that, incident to a divorce, the [c]hancery

[c]ourt has authority, where the equities so suggest, to order a fair division of property

accumulated through the joint contributions and efforts of the parties.” Ferguson, 639 So.

2d at 924 (quoting Brown v. Brown, 574 So. 2d 688, 690 (Miss. 1990)). Therefore, the court

adopted guidelines in Ferguson for the equitable-distribution method for dividing marital

assets. Id. at 928. “There is no automatic right to an equal division of jointly-accumulated

4 property, but rather, the division is left to the discretion of the court.” Brown, 574 So. 2d at

691.

¶11. Thomas argues that the chancellor erred by failing to classify Ashley’s retirement

account as marital property. We reexamine the chancellor’s application of the Ferguson

factors, but in doing so, we do not conduct a new Ferguson analysis. Phillips v. Phillips, 904

So. 2d 999, 1001 (¶8) (Miss. 2004). Instead, we “review[] the judgment to ensure that the

chancellor followed the appropriate standards and did not abuse [her] discretion.” Id. In the

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