Traci Fallow, V. Troy Fallow

CourtCourt of Appeals of Washington
DecidedApril 30, 2024
Docket57677-5
StatusPublished

This text of Traci Fallow, V. Troy Fallow (Traci Fallow, V. Troy Fallow) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Traci Fallow, V. Troy Fallow, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

April 30, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Marriage of: No. 57677-5-II

TRACI DANYEL FALLOW,

Respondent,

and

TROY LYNN FALLOW, PUBLISHED OPINION

Appellant.

LEE, P.J. — Troy Fallow appeals a commissioner’s order imposing sanctions pursuant to

CR 11 based on his counsel’s continued objection to a commissioner’s authority to hear a contested

dissolution trial. Troy1 also appeals a superior court order denying a motion for reconsideration,

which was entered in response to Troy’s motion for revision of the commissioner’s ruling

imposing sanctions.

Because Troy’s counsel advanced an argument without legal basis and failed to conduct a

reasonable inquiry into legal authorities, and because the relevant legal authority allows

commissioners to preside over a contested dissolution trial, we hold that the commissioner did not

err in imposing sanctions. However, because the superior court issued an order denying a motion

for reconsideration instead of an order addressing the motion for revision, the superior court’s

1 This opinion refers to the parties by their first names for clarity. We intend no disrespect. No. 57677-5-II

order was issued on the wrong legal basis. Therefore, we reverse the superior court’s order denying

reconsideration and remand for further proceedings consistent with this opinion.

FACTS

Troy and Traci Fallow married in 2004. They separated in 2020, and in 2021, Traci filed

for dissolution. Over the course of 2021, Troy and Traci disputed several aspects of their

separation, including child support, spousal support, and distribution of assets. In February 2022,

the dissolution was set for a one-day, non-jury trial on March 2. At the pretrial conference on

February 28, the parties indicated they were not prepared to go to trial.

Trial was re-set for September 30. On September 27, Troy’s counsel, Steven McNeill,

called the superior court administrator to confirm the judge assigned to the trial. The court

administrator informed McNeill that a commissioner2 had been assigned by the presiding judge.

McNeill told the court administrator that he did not believe a commissioner could hear a

“final divorce trial” and “there were no stipulations regarding a court commissioner sitting as a

pro tempore Judge.” Clerk’s Papers (CP) at 238. The court administrator stated that the

2 The assigned commissioner was appointed in 2021. The order appointing the commissioner stated:

IT IS HEREBY ORDERED that pursuant to the provisions of chapter 2.24.010 and 2.24.040, Revised Code of Washington, Daryl A Rodrigues, be and hereby is appointed as a Court Commissioner . . . and shall qualify as such by taking and subscribing an oath as provided by law. He shall have all the powers of a Court Commissioner as provided by the law of the State of Washington.

Mot. to Suppl. the Rec., Ex. A., (July 12, 202)

2 No. 57677-5-II

commissioner was assigned by the superior court presiding judge and that commissioners could

hear final dissolution trials.

On September 28, McNeill called Traci’s counsel, James Parker, to discuss his reservations

about a commissioner being assigned to the trial. According to McNeill, Parker agreed with him

that a commissioner could not hear a final dissolution trial. However, Parker suggested that they

maintain the trial date and use it instead as a settlement discussion opportunity.

Parker had previously learned on September 23 that a commissioner had been assigned to

the trial. According to Parker, when Parker spoke with McNeill, McNeill allegedly did not inform

Parker that he intended to object to the commissioner hearing the case; rather, McNeill stated that

“he preferred the issue of the commissioner’s authority be resolved first,” without further

explanation. CP at 214.

On September 29, Parker filed Traci’s proposed exhibits. McNeill then filed Troy’s pretrial

statement and proposed exhibits. According to Parker, he understood McNeill’s filings to mean

that McNeill was actually prepared to proceed to trial despite his initial reservations. According

to McNeill, he only filed the pretrial statement and proposed exhibits in response to Parker’s

submissions.

On September 30, at the start of trial, McNeill raised the issue of the commissioner’s

authority. When the commissioner asked why McNeill was raising the issue at the commencement

of trial, as opposed to before trial, McNeill stated, “I don’t know what more I can do in terms of

raising the issue.” Verbatim Rep. of Proc. (VRP) (Sept. 30, 2022) at 9. Parker suggested that the

parties stipulate on the record to the commissioner acting as a judge pro tempore. However,

3 No. 57677-5-II

McNeill stated that he wanted a ruling from the court on the issue of the commissioner’s authority

first and would then consult with Troy.

The commissioner took a brief recess to research the issue. Upon return, the commissioner

concluded that under the Washington State Constitution, it had the authority to proceed with the

trial and that its authority was not limited by RCW 2.24.040.3 However, McNeill continued to

object to the commissioner’s authority, citing language from the Washington Constitution4 and

RCW 2.24.040(9).5 Specifically, McNeill took issue with the definition of “‘at chambers’” in the

Washington Constitution. VRP (Sept. 30, 2022) at 14. McNeill stated, “I couldn’t find a definition

of what ‘at chambers’ means. I assume what that means is ex parte, at chambers.” VRP (Sept. 30,

2022) at 14.

Because of McNeill’s continued objection, the commissioner stated: “I have the authority

to conduct this trial under advisement and both parties are going to submit briefing.” VRP (Sept.

3 RCW 2.24.040 enumerates 15 specific powers of court commissioners. 4 The relevant portion of the Washington State Constitution states:

There may be appointed in each county, by the judge of the superior court having jurisdiction therein, one or more court commissioners, not exceeding three in number, who shall have authority to perform like duties as a judge of the superior court at chambers, subject to revision by such judge, to take depositions and to perform such other business connected with the administration of justice as may be prescribed by law.

WASH. CONST. art. IV, § 23. 5 RCW 2.24.040(9) provides that court commissioners shall have the authority “[t]o hear and determine ex parte and uncontested civil matters of any nature.”

4 No. 57677-5-II

30, 2022) at 16. The commissioner instructed the parties to contact court administration to set

another hearing date within the next 10 days to resolve the issue of the commissioner’s authority.

After the commissioner ruled, Parker orally moved for attorney fees and sanctions, in part

because McNeill’s objection to the commissioner’s authority was untimely and because Traci had

flown to Washington from out of state to participate in the trial. The commissioner determined it

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

Related

King County v. Williamson
830 P.2d 392 (Court of Appeals of Washington, 1992)
Olson v. Chase
531 P.2d 508 (Court of Appeals of Washington, 1975)
Bryant v. Joseph Tree, Inc.
829 P.2d 1099 (Washington Supreme Court, 1992)
Eller v. EAST SPRAGUE MOTORS & RV'S, INC.
244 P.3d 447 (Court of Appeals of Washington, 2010)
West v. STATE, ASS'N OF COUNTY OFFICIALS
252 P.3d 406 (Court of Appeals of Washington, 2011)
Williams v. Williams
232 P.3d 573 (Court of Appeals of Washington, 2010)
State v. Karas
32 P.3d 1016 (Court of Appeals of Washington, 2001)
BUILDING INDUSTRY ASS'N v. McCarthy
218 P.3d 196 (Court of Appeals of Washington, 2009)
State Ex Rel. Lockhart v. Claypool
232 P. 351 (Washington Supreme Court, 1925)
Christy Jo Lyle v. Keith James Lyle
199 Wash. App. 629 (Court of Appeals of Washington, 2017)
State v. Karas
108 Wash. App. 692 (Court of Appeals of Washington, 2001)
Building Industry Ass'n v. McCarthy
152 Wash. App. 720 (Court of Appeals of Washington, 2009)
In re the Marriage of Williams
156 Wash. App. 22 (Court of Appeals of Washington, 2010)
Eller v. East Sprague Motors & R.V.'s, Inc.
159 Wash. App. 180 (Court of Appeals of Washington, 2010)
West v. Washington Ass'n of County Officials
162 Wash. App. 120 (Court of Appeals of Washington, 2011)
Stiles v. Kearney
277 P.3d 9 (Court of Appeals of Washington, 2012)
In re McCann
424 P.3d 234 (Court of Appeals of Washington, 2018)
State v. Goss
895 P.2d 861 (Court of Appeals of Washington, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Traci Fallow, V. Troy Fallow, Counsel Stack Legal Research, https://law.counselstack.com/opinion/traci-fallow-v-troy-fallow-washctapp-2024.