Frederick Renee Ruffin v. Antoine Maurice Roberts
2014 D.C. App. LEXIS 110
| D.C. | 2014Background
- Ruffin challenges a Consent Custody Order awarding sole legal and physical custody of A.R. to Roberts.
- The order followed a status hearing during divorce proceedings where custody and visitation were discussed.
- Ruffin was incarcerated for an arson offense around this time, affecting her participation.
- The court granted Roberts sole custody based on mutual consent, separating custody from visitation.
- Ruffin sought third-party visitation with maternal aunts, which the court denied for lack of statutory authority.
- The court concluded it lacked authority to order third-party visitation and found the Military Act inapplicable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Ruffin unconditionally consent to Roberts' custody? | Ruffin's consent was conditioned on visitation | Ruffin unconditionally consented to custody | Consent was unconditional; order upheld |
| Did the trial court have authority to order third-party visitation? | Court should order third-party visitation in best interests | Authority limited to parties; no third-party visitation | Court lacked authority to grant third-party visitation |
| Is the Military Act applicable to authorize third-party visitation? | Military Act supports third-party visitation | Not applicable; Ruffin not deployed military | Military Act not applicable; no authority granted |
Key Cases Cited
- Jordan v. Jordan, 14 A.3d 1136 (D.C. 2011) (clarifies distinctions between custody and visitation issues; conduct of hearings)
- Wilkins v. Ferguson, 928 A.2d 655 (D.C. 2007) (courts have broad discretion to fashion visitation in child's best interests)
- Lewis v. Lewis, 637 A.2d 70 (D.C. 1994) (best interests standard in custody matters; parental rights emphasized)
- T.S. v. M.C.S., 747 A.2d 159 (D.C. 2000) (limits on awarding custody to non-parties; any custody between parents only)
- Troxel v. Granville, 530 U.S. 57 (U.S. 2000) (recognizes fundamental parental rights in child-rearing decisions)
- In re K.D., 26 A.3d 772 (D.C. 2011) (distinguishes visitation/adoption context; weight given to custodian's decisions may be limited by statutes)
- In re J.F., 615 A.2d 594 (D.C. 1992) (parental rights and protections under law; custody decisions must protect rights of parents)