Racheal Goodlett v. Brandon Bolin
2024-CA-0441
| Ky. Ct. App. | Jun 27, 2025Background
- Racheal Goodlett (Mother) and Brandon Bolin (Father) are the unmarried parents of a 2019-born child who had primarily lived with Mother in Kentucky; Father resided in Georgia.
- No prior custody order existed; Father filed for custody in December 2023, alleging concerns for the child's safety in Mother's new household after she married Jonathan Raines, who had a criminal and substance abuse history.
- Evidence at trial focused largely on the environment in Mother's home (drug use, firearms, cleanliness, and the involvement of Raines), Father's efforts to see the child, and Mother's restriction of Father's contact.
- After a hearing, the family court granted joint legal custody but designated Father as the primary residential parent, restricting Raines from being a caretaker during Mother's parenting time.
- Mother appealed, challenging the factual findings, legal conclusions, and the timesharing schedule under Kentucky law.
Issues
| Issue | Goodlett's Argument | Bolin's Argument | Held |
|---|---|---|---|
| Were findings of fact clearly erroneous? | All relevant factors should weigh against Father; findings ignored evidence | Substantial evidence supports risk from Raines and Mother's conduct | No clear error; findings supported |
| Were legal conclusions unsupported by evidence? | Order does not accord with the record; legal conclusions flawed | Evidence justified concerns about Mother's judgment and safety in the home | Order supported by substantial evidence |
| Did the court follow statutory best interest factors? | Failed to properly weigh child's longstanding residence with Mother | Court followed KRS 403.270 and weighed risks objectively | Court had discretion in weighting |
| Did the court err on timesharing schedule? | Did not maximize Mother's parenting time; overly relied on local guidelines | Schedules reflect best interest due to distance and school factors | Issue not preserved; no palpable error |
Key Cases Cited
- Frances v. Frances, 266 S.W.3d 754 (Ky. 2008) (sets out standard of review and best interests custody analysis)
- Gonzalez v. Dooley, 614 S.W.3d 515 (Ky. App. 2020) (custody decisions reviewed for abuse of discretion; factual findings for clear error)
- Moore v. Asente, 110 S.W.3d 336 (Ky. 2003) (appellate courts defer to trial court on witness credibility and factual determinations)
- Drury v. Drury, 32 S.W.3d 521 (Ky. App. 2000) (family courts have wide discretion in determining custody arrangements)