West Virginia Department of Health and Human Resources Bureau for Child Support Enforcement v. Shawn O.

CourtIntermediate Court of Appeals of West Virginia
DecidedSeptember 5, 2023
Docket23-ica-8
StatusPublished

This text of West Virginia Department of Health and Human Resources Bureau for Child Support Enforcement v. Shawn O. (West Virginia Department of Health and Human Resources Bureau for Child Support Enforcement v. Shawn O.) is published on Counsel Stack Legal Research, covering Intermediate Court of Appeals of West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
West Virginia Department of Health and Human Resources Bureau for Child Support Enforcement v. Shawn O., (W. Va. Ct. App. 2023).

Opinion

IN THE INTERMEDIATE COURT OF APPEALS OF WEST VIRGINIA

FILED WEST VIRGINIA DEPARTMENT September 5, 2023 OF HEALTH AND HUMAN RESOURCES, EDYTHE NASH GAISER, CLERK BUREAU FOR CHILD SUPPORT ENFORCEMENT, INTERMEDIATE COURT OF APPEALS

Petitioner Below, Petitioner, OF WEST VIRGINIA

vs.) No. 23-ICA-8 (Fam. Ct. Jefferson Cnty. No. FC-19-2022-D-107)

SHAWN O., Respondent Below, Respondent

MEMORANDUM DECISION

Petitioner West Virginia Department of Health and Human Resources, Bureau of Child Support Enforcement (“BCSE”) appeals the Family Court of Jefferson County’s “Order Denying Motion to Reconsider” entered on December 12, 2022. The issue on appeal is whether BCSE is required to serve a Uniform Interstate Family Support Act (“UIFSA”) 1 notice pursuant to Rule 4(k) of the West Virginia Rules of Civil Procedure. Shawn O. did not file a response. 2

This Court has jurisdiction over this appeal pursuant to West Virginia Code § 51- 11-4 (2022). After considering the parties’ arguments, the record on appeal, and the applicable law, this Court finds that there is error in the family court’s decision but no substantial question of law. This case satisfies the “limited circumstances” requirement of Rule 21(d) of the Rules of Appellate Procedure for reversal in a memorandum decision. For the reasons set forth below, the family court’s decision is reversed, and this case is remanded for further proceedings consistent with this decision.

1 UIFSA provides uniform rules for the enforcement of family support orders. Specific to this appeal, UIFSA provides processes and procedures in which support orders issued in one state can be registered in another state for enforcement purposes. All fifty states have adopted UIFSA. UIFSA was adopted by West Virginia in 2002. W. Va. Code § 48-16-1 (2002). 2 BCSE is represented by Mark French, Esq. Shawn O. is self-represented.

1 Shawn O. and Sherry N. are the biological parents of one child, who was born in Florida in 2000 when both parents lived in that state. Sometime in or around 2009, the parties separated. On October 14, 2009, the Circuit Court of Walton County, Florida entered an order directing Shawn O. to pay child support to Sherry N. Shawn O. moved to Charles Town, West Virginia sometime between the entry of the child support order and May of 2022.

On May 9, 2022, the BCSE received a UIFSA petition from the State of Florida, seeking to collect Shawn O.’s child support arrearages. On May 20, 2022, the BCSE initiated a case in the Family Court of Jefferson County for the purpose of registering the Florida child support order. 3 As required by West Virginia Code § 48-16-605(a) (2015), the Circuit Clerk of Jefferson County mailed Shawn O. a Notice of Registration of Foreign Order, along with attachments, on May 23, 2022, by registered mail, return receipt requested. Shawn O. received the documents and signed the mail receipt on May 31, 2022.

On October 24, 2022, the family court dismissed the action for failure to comply with the time limit for service of process rule set forth in Rule 4(k) of the West Virginia Rules of Civil Procedure. The BCSE filed a motion for reconsideration on October 26, 2022, along with evidence documenting that Shawn O. was sent the Notice of Registration of Foreign Order on May 23, 2022, by registered mail. The motion to reconsider was denied on December 12, 2022, again for failure to comply with Rule 4(k) of the West Virginia Rules of Civil Procedure. It is from the December 12, 2022, order that the BCSE now appeals.

Our standard of review of a family court’s order is well settled:

“In reviewing . . . a final order of a family court judge, we review the findings of fact made by the family court judge under the clearly erroneous standard, and the application of law to the facts under an abuse of discretion standard. We review questions of law de novo.” Syl. Pt., [in part,] Carr v. Hancock, 216 W. Va. 474, 607 S.E.2d 803 (2004).

Amanda C. v. Christopher P., __ W. Va. __, __, 887 S.E.2d 255, 258 (Ct. App. Nov. 18, 2022); accord W. Va. Code § 51-2A-14(c) (2005) (specifying standards for appellate court review of family court order).

3 The order registered with the family court reflects that Shawn O. is in arrears of $19,745.01 for the period of October 1, 2009, to April 22, 2022. 2 On appeal, BCSE argues that the family court erred when it applied Rule 4(k) of the West Virginia Rules of Civil Procedure 4 to UIFSA notice requirements. 5 UIFSA’s notice requirement states:

When a support order or income withholding order issued in another state or a foreign support order is registered, the clerk of the court shall notify the nonregistering party. The notice must be accompanied by a copy of the registered order and the documents and relevant information accompanying the order.

W. Va. Code § 48-16-605(a) (2015).

UIFSA directs that the family court “apply the procedural and substantive law generally applicable to similar proceedings” and that a foreign support order is “subject to the same procedures as an order issued by a tribunal of this state.” W. Va. Code § 48-16- 303(1) (2002); W. Va. Code § 48-16-603(b) (2015). The requirements in Rule 9(b) of the Rules of Practice and Procedure of Family Court are similar to the notice requirements set forth in UIFSA, which provide guidance as to what service is required in proceedings to register foreign support orders.

We find no West Virginia case law addressing service of process or notice issues concerning registering a foreign support order under UIFSA. We note that “[i]n applying and construing [UIFSA] consideration must be given to the need to promote uniformity of the law with respect to its subject matter among states that enact it.” W. Va. Code § 48-16- 901 (2002).

BCSE cites a Florida Court of Appeals case holding that registration is complete under UIFSA upon filing of the foreign order. Dep’t of Revenue v. Cuevas, 862 So. 2d 810, 811 (Fla. 4th Dist. Ct. App. 2003). In Cuevas, the support enforcement agency appealed an order dismissing the registration of an out-of-state child support order. Id. at 810. The trial

4 Rule 4(k) of the West Virginia Rules of Civil Procedure states:

If service of the summons and complaint is not made upon a defendant within 120 days after the filing of the complaint, the court, upon motion or on its own initiative after notice to the plaintiff, shall dismiss the action without prejudice as to that defendant or direct that service be effective within a specified time; provided that if the plaintiff shows good cause for the failure, the court shall extend the time for service for an appropriate period. 5 Shawn O. did not file a response brief. Accordingly, this Court is entitled to assume that Shawn O. agrees with BCSE’s view of the issues presented. W. Va. R. App. P. 10(d).

3 court sua sponte dismissed the action because the support enforcement agency did not serve the respondent within the time allotted under Florida Rule of Civil Procedure 1.070 and Family Law of Procedure 12.070. 6 Id. The Cuevas court found that the trial court erred in dismissing the case because “it was the obligation of the court, not the support enforcement agency, to assure that notice was properly sent.” Id. The court found that the support enforcement agency had fulfilled its obligation by filing the order and that if the court wished that service be sent in a different manner, then it was the court’s obligation to do so. Id.

The Court of Appeals of South Carolina has similarly declined to apply its civil procedure rule governing service of summons and complaint to UIFSA. S.C. Dep’t of Soc. Servs. v.

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Related

S.C. Department of Social Services Ex Rel. Jimmerson v. Johnson
688 S.E.2d 588 (Court of Appeals of South Carolina, 2009)
Carr v. Hancock
607 S.E.2d 803 (West Virginia Supreme Court, 2004)
Department of Revenue v. Cuevas
862 So. 2d 810 (District Court of Appeal of Florida, 2003)

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West Virginia Department of Health and Human Resources Bureau for Child Support Enforcement v. Shawn O., Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-virginia-department-of-health-and-human-resources-bureau-for-child-wvactapp-2023.