D. Bruce Stokstad v. Lucky Stokstad, 75438-6

Lucy and D. Bruce Stokstad litigated child support and related obligations for years; multiple judgments and liens were recorded against Lucy's residential property.
In Jan 2012 SSA paid $16,225 to the parties' child (W.S.); DCS later garnished Lucy's disability benefits and initially credited Lucy only $649, then in 2015 credited the full $16,225 to Lucy's support obligations.
Bruce contested DCS's credit administratively (Conference Board and an ALJ), but those administrative bodies declined to resolve or rejected his objection; he did not obtain judicial review.
Lucy moved (Feb 2016) to determine the amount needed to satisfy judgment liens so she could close a pending sale; Bruce sought a continuance to expand issues considered and to challenge the DCS credit.
Commissioner denied continuance, calculated liens (approximately $206,500), authorized entry of satisfactions to allow closing, and the superior court denied Bruce's revisions and awarded Lucy attorney fees for Bruce's intransigence.

Issue	Plaintiff's Argument (Lucy)	Defendant's Argument (Bruce)	Held
Whether denial of a two-week continuance was erroneous	Proceeding was limited to lien amounts to allow imminent sale; continuance would jeopardize sale	Needed continuance to prepare and to consolidate all outstanding support/enforcement issues	Denial was within court's discretion; continuance would have unreasonably delayed sale
Whether SSA lump-sum payment to child credited against Lucy's support obligation	DCS credit was lawful under RCW/WAC and applicable precedent; credit reduces liens	DCS credit violated state and federal law; Conference Board/ALJ decisions void or deprived due process	Credit of $16,225 to Lucy was lawful under Washington law; court relied on statutes and precedent
Whether 2011 judgment superseded earlier fee judgments (removal of duplicate liens)	2011 judgment included attorney fees for identical services, so earlier judgments should be removed	Bruce argued court erred in treating 2011 judgment as superseding earlier judgments	Court properly treated 2011 judgment as encompassing earlier identical fee awards; removal of duplicates appropriate
Whether court properly awarded Lucy attorney fees for Bruce's intransigence	Lucy sought fees for Bruce's counsel obstructing a limited lien-only proceeding	Bruce argued fees should be awarded to him for Lucy's intransigence	Award upheld: substantial evidence of counsel's foot-dragging/expansion of issues justified fees

In re Marriage of Moody, 137 Wn.2d 979 (review of commissioner rulings is de novo)
State v. Ramer, 151 Wn.2d 106 (review on appeal from superior court reviews the superior court decision)
Harris v. Drake, 116 Wn. App. 261 (standard for abuse of discretion on continuance motions)
Hizev v. Carpenter, 119 Wn.2d 251 (abuse of discretion principles)
In re Parentage of Fairbanks, 142 Wn. App. 950 (treatment of SSA disability payments as credit to support obligations)
In re Marriage of Briscoe, 134 Wn.2d 344 (RCW 26.18.190(2) unambiguously treats benefits paid to children as partial satisfaction)
In re Marriage of Greenlee, 65 Wn. App. 703 (attorney fees may be awarded for intransigence)
Saunders v. Lloyd's of London, 113 Wn.2d 330 (issues unsupported by cogent argument may be declined on appeal)