Vena v. Vena CA4/1

CourtCalifornia Court of Appeal
DecidedJune 17, 2025
DocketD083479
StatusUnpublished

This text of Vena v. Vena CA4/1 (Vena v. Vena CA4/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vena v. Vena CA4/1, (Cal. Ct. App. 2025).

Opinion

Filed 6/17/25 Vena v. Vena CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

CHRISTINE VENA, D083479

Plaintiff and Respondent,

v. (Super. Ct. No.: 19FL013961N) NICHOLAS VENA,

Defendant and Appellant.

APPEAL from orders of the Superior Court of San Diego County, Victor M. Torres, Judge. Affirmed in part; reversed in part; remanded with directions. Neumann Family Law and Sara R. Neumann for Defendant and Appellant. Law Office of Linda Cianciolo and Linda Cianciolo for Plaintiff and Respondent. Nicholas (Nick) Vena appeals a retroactive child support order and a domestic violence restraining order (DVRO). As to each of these orders, he contends the court abused its discretion and that he was prejudiced as a result. We conclude the court made a computational error that inflated its award for part of the time encompassed by the child support order. Hence we direct the court to recompute its award of child support for the affected period. In all other respects, we affirm the two orders. Both orders arise in the context of a contentious relationship between

Nick and his former wife, Christine Vena.1 Nick and Christine wed in 2002. Over the ensuing 17 years they had seven children, the eldest of whom now is 22 years old and the youngest of whom (twins) are six. In 2019, Nick and Christine separated. In 2021, the marriage was dissolved. In 2023, the court issued the two orders from which Nick appeals. I. GENERAL LEGAL PRINCIPLES Before turning to the two orders, and before discussing the evidence and legal principles that pertain to them, we discuss a pair of legal principles governing our review on appeal. These are the standard of review and the prejudicial error rule. A. Standard of Review As to both types of orders before us (child support and DVRO), it is well settled that our review is for an abuse of discretion. (See, e.g., In re Marriage of Lim & Carrasco (2013) 214 Cal.App.4th 768, 773 [child support]; Salmon v. Salmon (2022) 85 Cal.App.5th 1047, 1054 (Salmon) [DVRO].) A court abuses its discretion only when its decision is arbitrary, capricious, or patently absurd. (In re Caden C. (2021) 11 Cal.5th 614, 641 (Caden C.).) Consequently, a reviewing court has no authority to substitute its decision for that of the trial court if more than one inference can reasonably be deduced from the facts (ibid.), and it “should interfere only

1 Because the parties share the same last name, we refer to them here by their first names. We do so for the sake of clarity, intending no disrespect.

2 ‘ “if . . . under all the evidence, viewed most favorably in support of the trial court’s action, no judge could reasonably have made the order that he [or she] did.” ’ ” (In re Robert L. (1993) 21 Cal.App.4th 1057, 1067.) This said, a review for abuse of discretion may at times be tantamount to a review for substantial evidence. As our Supreme Court has said, “where . . . ‘the appellate court will be evaluating the factual basis for an exercise of discretion, there likely will be no practical difference in application of the two standards.’ ” (Caden C., supra, 11 Cal.5th at p. 641; cf. Salmon, supra, 85 Cal.App.5th at p. 1054 [“ ‘abuse of discretion standard is not a unified standard; the deference it calls for varies according to the aspect of a trial court’s ruling under review’ ”].) Under the substantial evidence standard, “determinations should ‘be upheld if . . . supported by substantial evidence, even though substantial evidence to the contrary also exists and the trial court might have reached a different result had it believed other evidence.’ ” (Caden C., supra, 11 Cal.5th at p. 640; see also Schmidt v. Superior Court (2020) 44 Cal.App.5th 570, 582 [“Our job is only to see if substantial evidence exists to support the verdict in favor of the prevailing party, not to determine whether substantial evidence might support the losing party’s version of events.”].) “This traditional standard of review is highly deferential. It has three pillars. First, we accept all evidence supporting the trial court’s order. Second, we completely disregard contrary evidence. Third, we draw all reasonable inferences to affirm the trial court. . . . Under this standard of review, parties challenging a trial court’s factfinding bear an ‘enormous burden.’ ” (Schmidt, at pp. 581– 582.) B. Prejudicial Error Rule If our review of the trial court proceedings reveal error, then we must further consider whether such error is harmless. (F.P. v. Monier (2017)

3 3 Cal.5th 1099, 1107–1108.) As our Supreme Court has observed, “ ‘reversible error is a relative concept,’ ” “ ‘whether a slight or gross error is ground for reversal depends on the circumstances in each case,’ ” and a reviewing court reverses a judgment “ ‘only when the court, “after an examination of the entire cause, including the evidence,” is of the “opinion” that it is reasonably probable that a result more favorable to the appealing party would have been reached in the absence of the error.’ ” (Cassim v. Allstate Ins. Co. (2004) 33 Cal.4th 780, 800 (Cassim); see also Sabato v. Brooks (2015) 242 Cal.App.4th 715, 724–725 (Sabato).) “A reasonable probability for these purposes does not mean an absolute probability” (Sabato, supra, 242 Cal.App.4th at p. 725), nor does it mean “ ‘more likely than not.’ ” (Cassim, supra, 33 Cal.4th at p. 800.) Rather, it means “ ‘merely a reasonable chance, more than an abstract possibility’ ” (ibid.), and “[t]he test is satisfied, and prejudice appears, if the case presents ‘an equal balance of reasonable probabilities.’ ” (Sabato, at p. 725.) In applying the principles discussed above to the two orders from which Nick appeals, we address the child support order before turning to the DVRO. II. CHILD SUPPORT ORDER A. Background The child support proceedings in this case commenced in the spring of 2020, when Christine first filed a request seeking child support. Several months later, at the parties’ request, the court appointed a privately compensated temporary judge (private judge) to resolve child support issues and to address various other matters. The private judge entered a child support order. However, she subsequently recused herself; and in 2022, at Nick’s request, the court ruled that all of the private judge’s orders were void.

4 In 2023,Christine filed a new request for child support. In a declaration, she asked that such support be awarded retroactively, in light of the fact that the support orders issued by the private judge had been deemed void. Nick filed multiple declarations in opposition to this request. There then ensued two hearings, a child support order, and, following the submission of additional declarations by the parties, the amended child support order that is a subject of this appeal. In the amended child support order, the court found that “[b]oth parties can work . . . [b]ut apparently neither party chooses to work.” Then it turned to the request for retroactivity. Noting that it was Nick who had moved for the private judge’s orders to be declared void and that Nick had failed to pay the child support the private judge had ordered, the court concluded: “It is disingenuous for [Nick] to oppose retroactivity.” Then the court proceeded to award child support for each of five distinct periods of time spanning May 1, 2020, through April 30, 2023. B. Analysis On appeal, Nick does not challenge the court’s determination that child support should be awarded retroactively.

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Related

Marriage of Lim and Carrasco CA6
214 Cal. App. 4th 768 (California Court of Appeal, 2013)
People v. Bradley
132 Cal. App. 3d 737 (California Court of Appeal, 1982)
San Joaquin County Department of Human Services v. Gary L.
21 Cal. App. 4th 1057 (California Court of Appeal, 1993)
Cassim v. Allstate Insurance
94 P.3d 513 (California Supreme Court, 2004)
Sabato v. Brooks CA3
242 Cal. App. 4th 715 (California Court of Appeal, 2015)
F.People v. Monier
405 P.3d 1076 (California Supreme Court, 2017)
Jameson v. Desta
420 P.3d 746 (California Supreme Court, 2018)

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Bluebook (online)
Vena v. Vena CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vena-v-vena-ca41-calctapp-2025.