Whitney Nicole Cochran v. Stephen Carl Loewer

CourtLouisiana Court of Appeal
DecidedOctober 4, 2023
DocketCA-0023-0185
StatusUnknown

This text of Whitney Nicole Cochran v. Stephen Carl Loewer (Whitney Nicole Cochran v. Stephen Carl Loewer) 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
Whitney Nicole Cochran v. Stephen Carl Loewer, (La. Ct. App. 2023).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

23-185

WHITNEY NICOLE COCHRAN

VERSUS

STEPHEN CARL LOEWER

**********

APPEAL FROM THE TWENTY SEVENTH JUDICIAL DISTRICT COURT PARISH OF ST. LANDRY, NO. 09-0877 HONORABLE A. GERARD CASWELL, DISTRICT JUDGE

CHARLES G. FITZGERALD JUDGE

Court composed of Candyce G. Perret, Charles G. Fitzgerald, and Guy E. Bradberry, Judges

AFFIRMED. Julie Koren Vaughn Felder Julie Vaughn Felder, A.P.L.C. P.O. Box 80399 Lafayette, Louisiana 70598-0399 (337) 856-3444 (337) 856-3447 (fax) Counsel for Defendant/Appellant: Stephen Carl Loewer

Lynette Young Feucht Law Firm of Lynette Young Feucht P.O. Box 1067 Eunice, Louisiana 70535-1067 (337) 550-1115 (337) 546-0900 (fax) Counsel for Plaintiff/Appellee: Whitney Nicole Cochran FITZGERALD, Judge.

This appeal arises from a judgment modifying custody and denying contempt.

FACTS AND PROCEDURAL HISTORY

Whitney Nicole Cochran and Stephen Carl Loewer were never married but

are the parents of a fourteen-year-old son, Camdyn. In April 2009, paternity and

custody were established by stipulated judgment. In essence, the parties agreed to

joint legal custody, to Whitney being named the domiciliary parent, to a schedule of

physical custody, and to a joint custody implementation plan.

In the years that followed, Whitney and Stephen filed numerous custody

pleadings, resulting in ongoing litigation and ever-changing custody judgments. By

stipulated judgment dated August 26, 2013, for example, the parties agreed to

increase Stephen’s custodial periods with Camdyn. Four years later, by stipulated

judgment dated October 2, 2017, Stephen’s time periods were further increased and

changes were made to the implementation plan. And two years after that, by

stipulated judgment dated September 5, 2019, the parties agreed to change the

domiciliary parent from Whitney to Stephen; the parties also agreed to shared

(50/50) physical custody.

Next, in June 2021, Whitney filed a rule to modify custody, alleging changes

in the child’s schooling and extracurricular activities. Several months later, Whitney

dismissed her rule with prejudice.

A few weeks after that, in November 2021, Stephen filed a rule for contempt

and modification of custody. Whitney responded in April 2022, by filing her own

action for contempt and modification of custody. Stephen then supplemented his

pleadings in June 2022. He also refixed three contempt motions that he had

previously filed. The trial of all matters was held on August 22-24, 2022. At the close of

evidence, the trial court ruled from the bench with extensive oral reasons. This

ruling was reduced to a written final judgment signed on December 19, 2022.

Oversimplifying slightly, the trial court awarded joint custody of Camdyn to

Whitney and Stephen, and the court designated Whitney as the domiciliary parent.

Stephen was granted physical custody on alternating weekends from Friday after

school until the following Monday morning and on alternating weeks from

Wednesday at 5:00 p.m. until the following Friday morning. For summer vacation

and school holidays, the parties were given equal time. The court further ordered

that the child be enrolled at St. Edmund Catholic School in Eunice. And finally, the

court allocated the legal authority and responsibility of the parents in a joint custody

implementation plan.

It is from the December 19, 2022 judgment that both parties appeal. And on

appeal, Stephen asserts seven assignments of error:

1. The trial court erred in modifying custody to name Whitney domiciliary parent and reducing Stephen’s custodial time. A proper application of the Civil Code Article 134 factors should have maintained Stephen as the domiciliary parent and awarded Whitney a more limited schedule during the school year.

2. The trial court erred when it failed to give any weight to the presumption that the decision made by the domiciliary parent regarding schooling (a “major decision”) was in the best interest of the minor child and ordered the minor child to attend a school neither parent requested, thereby substituting the judgment of the court for that of both parents. Further, this issue was not properly before the court.

3. The trial court erred when it ordered the minor child to participate on a particular travel baseball team given that, absent agreement of the parties, the decision-making authority regarding extracurricular activities (not a “major decision”) belongs [sic] is that of the domiciliary parent and is not subject to judicial review.

4. The trial court erred in unilaterally altering the parties’ agreements regarding transportation of the minor child for

2 extracurricular activities and regarding make-up time for Stephen when neither party requested their agreements in this regard be modified.

5. The trial court erred in failing to hold Whitney in contempt of court for her numerous violations of the provisions of the judgments in place.

6. The trial court erred when it considered factual allegations raised in Whitney’s June 29, 2021 Rule that was subsequently dismissed with prejudice.

7. The trial court erred, as a matter of public policy, to award primary custody to Whitney because her deliberate choices made the agreed upon custodial provisions more difficult on her, i.e., her loss of a flexible job resulting from her illegal behavior and her moving to a house further from Lafayette two months before trial.

Whitney timely answered the appeal, and she asserts the following assignment

of error:

The trial judge erred in not recognizing Stephen’s willful disobedience to the 2019 judgment by using vulgar and berating language to Whitney on multiple occasions, speaking disrespectfully to her family members regarding her, failing to inform Whitney that he had enrolled Camdyn in Carencro Catholic, ignoring her input, and finally, failing to maintain Camdyn’s extracurricular activities.

LAW AND ANALYSIS

I. Custody Issues

All of Stephen’s assignments of error, apart from number five, involve the trial

court’s modification of custody. These assignments will therefore be discussed

together.

The paramount consideration in any determination of custody, including

actions to change custody, is the best interest of the child. La.Civ.Code art. 131;

Evans v. Lungrin, 97-541, 97-577 (La. 2/6/98), 708 So.2d. 731. In Evans, the

supreme court clarified that “where the original custody decree is a stipulated

judgment, the party seeking modification must prove (1) that there has been a

material change in circumstances since the original custody decree was entered, and

3 (2) that the proposed modification is in the best interest of the child.” Id. at 738. A

stipulated custody judgment, as explained in Evans, is one where the parties consent

to a custodial arrangement and no evidence of parental fitness is presented to the

court. Here, all previous custody decrees are stipulated judgments.

On appeal, custody determinations are reviewed under the abuse of discretion

standard. Marksbury v. Marksbury, 16-526 (La. 3/24/16), 204 So.3d 180. Hence, a

trial court’s determination can only be set aside if it arises from an abuse of

discretion, such as when the factual finding is not supported by any fair interpretation

of the record. Gibson v. Bossier City Gen.

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Related

Rogers v. Dickens
959 So. 2d 940 (Louisiana Court of Appeal, 2007)
Evans v. Lungrin
708 So. 2d 731 (Supreme Court of Louisiana, 1998)
Lang v. Asten, Inc.
918 So. 2d 453 (Supreme Court of Louisiana, 2006)
Baker v. Baker
960 So. 2d 1264 (Louisiana Court of Appeal, 2007)
Gibson v. Bossier City General Hosp.
594 So. 2d 1332 (Louisiana Court of Appeal, 1991)
Burst v. SCHMOLKE
62 So. 3d 829 (Louisiana Court of Appeal, 2011)
Griffith v. Latiolais
48 So. 3d 1058 (Supreme Court of Louisiana, 2010)

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Whitney Nicole Cochran v. Stephen Carl Loewer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitney-nicole-cochran-v-stephen-carl-loewer-lactapp-2023.