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