Tiffany Nielsen v. Nakia Nielsen

CourtLouisiana Court of Appeal
DecidedNovember 22, 2023
Docket55,447-CA
StatusPublished

This text of Tiffany Nielsen v. Nakia Nielsen (Tiffany Nielsen v. Nakia Nielsen) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tiffany Nielsen v. Nakia Nielsen, (La. Ct. App. 2023).

Opinion

Judgment rendered November 22, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,447-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

TIFFANY NIELSEN Plaintiff-Appellee

versus

NAKIA NIELSEN Defendant-Appellant

Appealed from the Fifth Judicial District Court for the Parish of Richland, Louisiana Trial Court No. 46,400

Honorable Will Barham, Judge

NEWMAN OLIVEAUX & MAGEE, LLP Counsel for Appellant By: Trey N. Magee

LAW OFFICES OF DAWN H. MIMS Counsel for Appellee, By: Dawn (Mims) Hendrix Tiffany Nielson

MICHAEL R. ELLINGTON Counsel for Intervenor- Assistant District Attorney Appellee, State of Louisiana DCFS

Before PITMAN, STONE, and ELLENDER, JJ.

PITMAN, J., concurs in the results.

ELLENDER, J., concurs in the results. STONE, J.

This civil appeal arises from the Fifth Judicial District Court, the

Honorable Will Barham, presiding. The plaintiff-appellee, Tiffany Nielsen

(“Tiffany”), and the defendant-appellant, Nakia Nielson (“Nakia”), are the

mother and father of J.N., J.S.N., and J.M.N. Tiffany filed a rule to modify

custody, visitation, for contempt of court, court costs, and attorney fees, and

a motion for immediate return of the minor child. Nakia filed an Answer

and Reconventional Demand requesting that he be awarded sole custody of

their eldest child, J.N. The trial court denied both parties’ motions to modify

custody and ordered that the parents continue to have joint legal custody.

The trial court ordered that Nakia’s nondomiciliary custody or visitation

occur in the State of Louisiana, that J.N. be returned to Tiffany, and that the

costs be equally assessed to each party. The trial court further ordered that

Nakia not be held in contempt for failure to return J.N. and for failure to pay

child support. The trial court also deferred the issue of child support to the

Department of Children and Family Services, Child Support Enforcement

(“DCFS”) division. From this judgment, Nakia appeals.

For the reasons set forth below, we reverse the judgment of the trial

court and remand for further proceedings.

FACTS AND PROCEDURAL BACKGROUND

Tiffany and Nakia were married on August 21, 2010, in Delhi,

Louisiana, and three children were born of the marriage, namely: J.N. (DOB:

11/29/08), J.S.N. (DOB: 01/01/13), and J.M.N. (DOB: 05/23/15). Tiffany

and Nakia separated in 2018 and divorced on March 12, 2020. This matter

first came to trial pursuant to Tiffany’s petition for sole custody in October 2018. At the conclusion of the 2018 trial, Tiffany’s request for sole custody

was denied, the parents were awarded joint legal custody, and Tiffany was

designated the domiciliary parent. Nakia was also ordered to pay $1,100 in

child support per month. A considered decree reflecting that ruling was

executed on August 13, 2019.

In 2022 (pursuant to the court order), the children spent the summer

with Nakia in Ohio. At the end of the visit, Nakia returned J.S.N. and

J.M.N. to Tiffany but refused to return J.N. Also at that time, Nakia was

nearly $30,000 in child support arrears.1 As a result of Nakia’s failure to

adhere to the court ordered custody schedule, Tiffany filed the

aforementioned rules, asserting among other things, that: (1) separating the

children will have a harmful and deleterious effect on all the minor children;

(2) since the 2019 judgment, Nakia has moved eight separate times across

several states and does not have a stable residence; (3) Nakia lacks stable

employment and is not financially supporting the children; (4) Nakia

willfully violated the current custody order by keeping J.N. past his allotted

visitation time; (5) during his periods of physical custody of the children,

Nakia willfully interferes with communication between the minor children

and their mother; (6) Nakia has not complied with the custody schedule and

considers visitations to be at his convenience; (7) Nakia neither

communicates nor provides an address to Tiffany where he currently resides

or to where he is relocating; (8) Nakia does not constructively co-parent with

Tiffany, nor is he involved in any decision-making regarding the children’s

educational, medical, or other decisions concerning their welfare; and (9)

1 During his testimony at trial, Nakia admitted to not returning custody of J.N. to Tiffany and to not paying child support as ordered. 2 Nakia has willfully failed and refused to pay court-ordered child support;

and, as a result, should be held in contempt.

The two-day trial commenced on November 22, 2022, at which time

Nakia filed an answer and reconventional demand. In his reconventional

demand, Nakia asserted that: (1) due to J.N.’s unhappiness, poor academic

performance, and behavioral issues in Louisiana, it would be best that J.N.

live with him; (2) he did not return J.N. to Tiffany at the end of his visitation

period because he believed it was in J.N.’s best interest and that returning

J.N. to Tiffany would be deleterious to the child; (3) J.N. begged to stay in

Ohio with Nakia and did not want to return to Louisiana to live; (4) he

believed that he should not be held in contempt because he was justified in

keeping J.N. and was in the process of filing for sole custody of J.N. when

he was served with Tiffany’s rules to show cause; and (5) he has made

substantial child support payments to Tiffany and has filed for a reduction in

child support.

During the trial, several witnesses were called by the parties.

However, without the request of either party, the trial court called Mr. Willie

Ray Nielsen (“Mr. Nielsen”), Nakia’s father, as its own witness. Mr.

Nielsen agreed to appear voluntarily. Prior to his testimony, the trial court

stated, “I want you to know … that [Mr. Nielsen’s appearance] was

exclusively my idea; you’re not in any kind of trouble or anything like that.

I just wanted to hear from you so that I can make a good decision with

regard to these three minor children …” Counsel for Nakia cross-examined

Mr. Nielsen but subsequently objected to the trial court’s authority to call its

own witness.

3 In making its custody determination, the trial court stated that it

considered the best interests of the children, as well as any material changes

in circumstances that have occurred since the entry of the original custody

decree. With regard to contempt, the trial court defined contempt as “the

willful and contumacious disregard for a court order.” Although the trial

court found that Nakia’s conduct was willful, the trial court declined to hold

Nakia in contempt because the court did not think that Nakia had a

contumacious disregard for the court order. The trial court expressed that

Nakia’s “heart was in the right place.” As a result, the aforementioned

judgment was imposed.

Nakia appealed, asserting that by calling Mr. Nielsen as its own

witness, the trial court contravened La. C.E. art. 614(A) and that this error

was prejudicial to his case. Nakia argues that he did not have adequate time

to prepare for cross-examination of Mr. Nielsen; and, as a result, he was

severely prejudiced by his father’s testimony.

Tiffany answered the appeal, arguing the following assignments of

error: (1) the trial court erred in denying her motion for sole legal custody of

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

Related

Bergeron v. Bergeron
492 So. 2d 1193 (Supreme Court of Louisiana, 1986)
Leard v. Schenker
931 So. 2d 355 (Supreme Court of Louisiana, 2006)
Evans v. Lungrin
708 So. 2d 731 (Supreme Court of Louisiana, 1998)
In Re Merritt
391 So. 2d 440 (Supreme Court of Louisiana, 1980)
Key v. Monroe City School Board
32 So. 3d 1144 (Louisiana Court of Appeal, 2010)
Johnson v. Breck Const. Co.
743 So. 2d 296 (Louisiana Court of Appeal, 1999)
Duzon v. Stallworth
866 So. 2d 837 (Louisiana Court of Appeal, 2003)
Neumeyer v. Terral
478 So. 2d 1281 (Louisiana Court of Appeal, 1985)
Tracie F. v. Francisco D.
188 So. 3d 231 (Supreme Court of Louisiana, 2016)
State v. Free
127 So. 3d 956 (Louisiana Court of Appeal, 2013)
Pratt v. Culpepper
162 So. 3d 616 (Louisiana Court of Appeal, 2015)
Mosley v. Griffin
191 So. 3d 16 (Louisiana Court of Appeal, 2016)
Rockett v. Rockett
223 So. 3d 1227 (Louisiana Court of Appeal, 2017)
Duzon v. Stallworth
842 So. 2d 1110 (Supreme Court of Louisiana, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Tiffany Nielsen v. Nakia Nielsen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiffany-nielsen-v-nakia-nielsen-lactapp-2023.