Todd Puckett v. Tamara Senger

CourtCourt of Appeals of Virginia
DecidedSeptember 19, 2023
Docket1117223
StatusUnpublished

This text of Todd Puckett v. Tamara Senger (Todd Puckett v. Tamara Senger) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Todd Puckett v. Tamara Senger, (Va. Ct. App. 2023).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Fulton, Friedman and Raphael UNPUBLISHED

Argued at Lexington, Virginia

TODD PUCKETT MEMORANDUM OPINION* BY v. Record No. 1117-22-3 JUDGE FRANK K. FRIEDMAN SEPTEMBER 19, 2023 TAMARA SENGER

FROM THE CIRCUIT COURT OF AUGUSTA COUNTY Anne F. Reed, Judge

Juliet M. Bates (Bates Law PLLC, on brief), for appellant.

Tracy J. Evans, II (Evans Oliver, PLC, on brief), for appellee.

This domestic relations appeal involves disturbing facts, interpretation of a rather

complicated pre-nuptial agreement, and a bevy of rulings arising from the couple’s divorce and the

husband’s felonious misconduct. The trial court did a thorough and commendable job of sorting out

this dispute. We affirm the vast majority of rulings—but reverse two property awards involving

items that constituted husband’s separate property via inheritance.

BACKGROUND

Todd Puckett appeals a final decree of divorce entered by the Augusta County Circuit Court.

In 2009, Puckett and Tamara Senger entered into a premarital agreement that addressed spousal

support, separate property, waivers, household bills, property acquired during the marriage,

retirement benefits, and attorney fees. The parties married on May 16, 2009; one child was born to

the couple before the marriage. Senger had two daughters from an earlier relationship.

* This opinion is not designated for publication. See Code § 17.1-413(A). In 2020, Puckett pleaded guilty to 3 counts of aggravated sexual battery of his stepdaughter,

who was between the ages of 13 and 17, with offense dates between September 1, 2017 and March

31, 2018; the circuit court convicted Puckett and sentenced him to 15 years on each charge to run

concurrently, with 8 years suspended. One month later, Senger filed a complaint for divorce, which

she later amended. Senger sought a divorce based on Puckett’s felony conviction and sentence

exceeding one year. Puckett filed answers to the complaint and amended complaint.

Thereafter, Senger moved for declaratory judgment to determine the parties’ rights under the

premarital agreement. The parties appeared before the circuit court for a hearing, and the circuit

court held that the parties were “legally bound by the terms of their own Agreement.” The parties

then scheduled a final hearing to resolve the grounds of divorce and the distribution of property.

Before trial, the parties submitted a “Joint Statement Regarding Stipulations and Outstanding

Issues” which included a lengthy list of property to be awarded. The circuit court analyzed more

than fifty contested property items.

The circuit court granted Senger a divorce based on Puckett’s felony conviction and

sentence exceeding one year. The circuit court interpreted the language of the premarital agreement

to resolve the outstanding property issues and incorporated the premarital agreement into the final

decree of divorce. When the court divided property between the parties, it ruled that much property

that Puckett considered his separate property was to be treated as joint property.

With respect to the division of property, Puckett argued that he purchased numerous

possessions from an account that was comprised of his own income, which constituted separate

property—and that such purchases should have remained his separate property under the agreement.

Senger challenged his testimony—attacking both his credibility and arguing that Puckett’s alleged

income would not be sufficient to cover all these purchases. Similarly, she argued that Puckett

-2- purchased items using funds from joint accounts. The circuit court generally agreed with Senger as

to contested property designations.

Puckett also claimed several items as separate property via inheritance. The court agreed in

some instances, but, again, found his evidence insufficient to establish the majority of items claimed

as separate property. Puckett claimed two of these items (items 9 and 10 on the list of property)

were guns inherited from his father that should have been deemed his separate property. His

brother’s testimony supported this claim. There was no evidence to the contrary with respect to

items 9 and 10. The circuit court, nonetheless, treated these guns as joint property and split their

value between the parties.

The court also required Puckett to reimburse a share of Senger’s expenses in selling and

tending to “joint” properties. Puckett objected that he should not have been required to pay for

Senger’s efforts to sell the couple’s house and maintain their vehicles—and that, in any event,

Senger had failed to prove that her efforts in this regard benefited him. The court also awarded

child support against Puckett and also found Puckett responsible for costs involving counseling for

their daughter. (The pre-nuptial agreement waived spousal support.) The court denied Puckett a

recovery of attorney fees. Puckett had claimed an entitlement to fees based on Senger’s alleged

attempt to recover awards prohibited under the settlement agreement. The court further ruled that

the pre-nuptial agreement was not unconscionable.

The circuit court entered the final decree of divorce. Puckett timely appealed. Puckett

asserts on appeal that: the circuit court erred in (1) granting Senger a divorce pursuant to Code

§ 20-91(A)(3) without evidence of Puckett’s conviction for a felony and subsequent sentencing to a

term of imprisonment for greater than one year, (2) applying the statutory principles of equitable

distribution despite an express waiver of statutory remedies in the parties’ premarital agreement,

(3) requiring written evidence of separate title for property to be separate property under the -3- agreement, (4) designating certain property as marital property over evidence that the property was

separate property, (5) requiring Puckett to pay portions of expenses related to property titled in

Senger’s sole name contrary to the agreement, and (6) requiring Puckett to reimburse certain costs

of Senger without evidence that the costs were the results of actions taken for Puckett’s benefit.

Puckett also contends the circuit court erred in declining to award him attorney fees. Senger has

requested an award of appellate attorney fees. We address each argument in turn.

ANALYSIS

Standards of Review

“On appellate review, a divorce decree is presumed correct and will not be overturned if

supported by substantial, competent, and credible evidence.” Gottlieb v. Gottlieb, 19 Va. App. 77,

83 (1994); see also Sobol v. Sobol, 74 Va. App. 252, 272 (2022) (“[A]ll trial court rulings come to

an appellate court with a presumption of correctness.” (alteration in original) (quoting Wynnycky v.

Kozel, 71 Va. App. 177, 192 (2019))). “Where dual or multiple grounds for divorce exist, the trial

judge can use his sound discretion to select the grounds upon which he will grant the divorce.”

Fadness v. Fadness, 52 Va. App. 833, 840 (2008) (quoting Konefal v. Konefal, 18 Va. App. 612,

613-14 (1994)). “[T]his Court reviews the circuit court’s ‘interpretation of the parties’ agreement

de novo.’” Price v. Peek, 72 Va. App. 640, 646 (2020) (quoting Jones v. Gates, 68 Va. App. 100,

105 (2017)). “The determination of child support is a matter of discretion for the circuit court, and

therefore we will not disturb its judgment on appeal unless plainly wrong or unsupported by the

evidence.” Da’Mes v. Da’Mes, 74 Va. App.

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