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In the Matter of the Parenting & Support of: I.T. & C.T.
39642-8
Wash. Ct. App.
Oct 17, 2024
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Background

  • Kaleb Trinkle and Jennifer Lucker divorced, with two minor children at issue.
  • The superior court entered a permanent parenting plan after trial, restricting Trinkle’s interaction with the children due to findings of domestic violence and child abuse.
  • The parenting plan granted Lucker sole decision-making authority for the children.
  • Trinkle was ordered to pay monthly child support, back child support, and certain medical and reunification expenses.
  • On appeal, Trinkle failed to provide a trial transcript or exhibits, limiting appellate review.
  • The trial court's rulings were affirmed due to Trinkle’s failure to supply an adequate record.

Issues

Issue Trinkle's Argument Lucker's Argument Held
Parenting plan restrictions (domestic violence) Restriction was based on unsubstantiated allegations Restrictions based on the court’s factual findings Affirmed; findings treated as verities due to no record
Sole decision-making to Lucker Should have been shared; evidence did not justify exclusivity Appropriate due to domestic violence findings Affirmed; no record to review underlying evidence
Child support/custodial time calculation Child support should reflect 50/50 custody, was miscalculated Calculated based on findings of primary placement Affirmed; no record to challenge findings
Allocation of expenses (medical, reunification) Was unfair and not based on relative incomes Appropriate given findings of abuse Affirmed; no evidence in record on income differences

Key Cases Cited

  • In re Marriage of Chandola, 180 Wn.2d 632 (court reviews parenting plans for abuse of discretion)
  • In re Marriage of Katare, 175 Wn.2d 23 (parenting plans reviewed for manifest unreasonableness)
  • In re Marriage of Underwood, 181 Wn. App. 608 (family law decisions rarely disturbed on appeal)
  • In re Marriage of McDole, 122 Wn.2d 604 (assessment of best interests takes into account parents' testimony)
  • In re Custody of Shields, 157 Wn.2d 126 (actual behavior of the parties important for child’s best interest)
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Case Details

Case Name: In the Matter of the Parenting & Support of: I.T. & C.T.
Court Name: Court of Appeals of Washington
Date Published: Oct 17, 2024
Docket Number: 39642-8
Court Abbreviation: Wash. Ct. App.