Wills v. Wills

2016 Ark. App. 174
CourtCourt of Appeals of Arkansas
DecidedMarch 16, 2016
DocketCV-15-639
StatusPublished
Cited by1 cases

This text of 2016 Ark. App. 174 (Wills v. Wills) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wills v. Wills, 2016 Ark. App. 174 (Ark. Ct. App. 2016).

Opinion

Cite as 2016 Ark. App. 174

ARKANSAS COURT OF APPEALS DIVISION III No. CV-15-639

Opinion Delivered March 16, 2016

SHANE LEE WILLS APPEAL FROM THE WASHINGTON APPELLANT COUNTY CIRCUIT COURT [NO. DR-04-554] V. HONORABLE JOANNA TAYLOR, JUDGE THERESA WILLS AND MINOR CHILD APPELLEES AFFIRMED

LARRY D. VAUGHT, Judge

Shane Wills appeals the Washington County Circuit Court’s order denying his request

for a change of custody of his son and granting appellee Theresa Wills’s request for a change

of visitation. We affirm.

Shane Wills has a biological son whose biological mother, Cherokee Shea, has been

largely absent from his life. By all accounts, Theresa Wills, whom Shane married after his

divorce from Cherokee Shea, has been the child’s mother figure since he was an infant. In

2011, the court allowed Theresa to intervene in Shane and Cherokee’s custody case and

found that Theresa stood in loco parentis to the child. The order stated that Shane was the

custodial parent but that Theresa should be granted visitation. The court then entered an

agreed order stating Theresa would receive one-half of the child-support payments that

Cherokee Shea paid to Shane Wills. The following year, Shane and Theresa were divorced.

While there was conflicting testimony, it appears that their divorce was not amicable. On Cite as 2016 Ark. App. 174

March 25, 2014, Shane filed a motion to terminate Theresa’s visitation rights. He argued that

his acrimonious divorce from Theresa constituted a change in circumstances warranting

modification of visitation. After a hearing on the issue, the court found that there were no

changed circumstances warranting a change of custody but that circumstances had changed

enough to warrant a modification of visitation. The court ordered Shane and Theresa to

have equal visitation in a week-on, week-off format. The order also found Shane in

contempt for failing to give Theresa her share of the child-support payments he had

received. He was given sixty days to pay Theresa $5,040.82 in back child support. Shane

filed a timely notice of appeal.

In reviewing domestic-relations cases, appellate courts consider the evidence de novo.

Brown v. Brown, 2012 Ark. 89, at 6–7, 387 S.W.3d 159, 163. We will not reverse the circuit

court’s findings unless they are clearly erroneous. Id., 387 S.W.3d at 163. When our

determination of whether the circuit court’s findings are clearly erroneous turns on the

credibility of the witnesses, we give special deference to the superior position of the circuit

court to evaluate the witnesses, their testimony, and the child’s best interest. Baber v. Baber,

2011 Ark. 40, at 9–10, 378 S.W.3d 699, 705. A circuit court maintains continuing jurisdiction

over visitation and may modify or vacate those orders at any time when it becomes aware of

a change in circumstances or facts not known to it at the time of the initial order. Martin v.

Scharbor, 95 Ark. App. 52, 233 S.W.3d 689 (2006). Although visitation is always modifiable,

to promote stability and continuity for the children and to discourage repeated litigation of

the same issues, courts require more rigid standards for modification than for initial

determinations. Meins v. Meins, 93 Ark. App. 292, 218 S.W.3d 366 (2005). Thus, the party

2 Cite as 2016 Ark. App. 174

seeking a change in visitation has the burden to demonstrate a material change in

circumstances that warrants such a change. Baber, 2011 Ark. 40, at 9–10, 378 S.W.3d at 705.

The primary consideration regarding visitation is the best interest of the child. Meins,

93 Ark. App. 292, 218 S.W.3d 366. Important factors the court considers in determining

reasonable visitation are the wishes of the child, the capacity of the party desiring visitation

to supervise and care for the child, problems of transportation and prior conduct in abusing

visitation, the work schedule or stability of the parties, and the relationship with siblings and

other relatives. Id., 218 S.W.3d 366. Fixing visitation rights is a matter that lies within the

sound discretion of the circuit court. Id., 218 S.W.3d 366.

The Arkansas Supreme Court has repeatedly discussed the concept of in loco

parentis:

In Standridge v. Standridge, 304 Ark. 364, 803 S.W.2d 496 (1991), we cited Black’s Law Dictionary (5th ed. 1979) defining “in loco parentis ” as “in place of a parent; instead of a parent; charged factitiously with a parent’s rights, duties, and responsibilities.” In Moon Distributors v. White, 245 Ark. 627, 434 S.W.2d 56 (1968), we permitted a wrongful-death award to a decedent’s stepdaughter to whom the decedent stood in loco parentis, noting that the stepdaughter lived in the home with her stepmother “as mother and daughter.” Finally, this court has treated grandparents who stood in loco parentis differently from grandparents who did not. See Johnson v. Tompkins, 341 Ark. 949, 20 S.W.3d 385 (2000). In Johnson, we held that the grandparents had no right to present evidence on whether adoption would be in their grandchild’s best interest. Id. We distinguished our decisions in Quarles v. French, 272 Ark. 51, 611 S.W.2d 757 (1981), and Cox v. Stayton, 273 Ark. 298, 619 S.W.2d 617 (1981), in which we held that grandparents had standing to intervene in adoption proceedings involving their grandchildren, because the grandparents in those cases stood in loco parentis to their grandchildren. We hold that a court may award visitation to a stepparent who stands in loco parentis to a minor child when it determines that it is in the best interest of the child.

Bethany v. Jones, 2011 Ark. 67, at 10, 378 S.W.3d 731, 737 (quoting Robinson v. Ford-Robinson,

362 Ark. 232, 239–40, 208 S.W.3d 140, 144 (2005)).

3 Cite as 2016 Ark. App. 174

Shane argues on appeal that the trial court violated his constitutional right to direct

the control and upbringing of his child when it refused to terminate Theresa’s visitation

rights. It is fundamental that the Due Process Clause of the Fourteenth Amendment

protects the rights of parents to direct and govern the care, custody, and control of their

children. Bethany, 2011 Ark. 67, at 8, 378 S.W.3d at 736 (citing Troxel v. Granville, 530 U.S. 57

(2000) (plurality opinion) (declaring Washington State’s grandparent-visitation act

unconstitutional as applied) and Linder v. Linder, 348 Ark. 322, 72 S.W.3d 841 (2002) (holding

that Arkansas’s grandparent-visitation statute was unconstitutional as applied where it

violated a mother’s fundamental liberty interest under the due-process clause to parent her

child)).

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

Related

Lyndsay Bell v. Zachary Bell
2022 Ark. App. 279 (Court of Appeals of Arkansas, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2016 Ark. App. 174, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wills-v-wills-arkctapp-2016.