Richard S. Sullivan v. Jane Doe, 100 A.3d 171

Sullivan sexually abused Doe beginning when she was thirteen or fourteen, and the abuse continued for years, with predatory behavior and concealment efforts noted by the trial court.
Doe gave birth to the parties’ daughter in 2007; the child intermittently lived with Sullivan, but Doe and the child did not reside permanently with him and he did not provide consistent financial support during those periods.
Doe filed a complaint for protection from abuse in May 2011, resulting in a two-year PFA order, later extended to 2015, after which Sullivan had no contact with the child.
Sullivan filed a paternity complaint in December 2011; paternity was established in July 2012; interim orders denied Sullivan rights of contact and appointed a guardian ad litem.
A 2013 evidentiary hearing led to an order awarding Doe sole parental rights with no contact for Sullivan, excluding access to the child’s records, and a $38,019 arrearage in child support; Spurwink evaluation later indicated no compelling evidence of abuse.
Sullivan appealed the judgments; the court held the record supported its findings and affirmed the awards and arrearage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
whether the court properly found significant risk to minors	Sullivan argues no competent evidence supports risk findings	Doe argues the evidence establishes predatory, ongoing risk and a need to restrict contact	Yes; supported risk finding against Sullivan
whether denial of Sullivan’s contact with the child was in the child’s best interest	Sullivan contends contact should be allowed	Court properly denied contact at this time due to risk	Within the court’s discretion to deny contact
whether Sullivan should have access to the child’s records	Sullivan seeks access to records	Record denial aligned with sole custody and non-contact	Denied access; within discretion and tied to child’s best interests
whether the arrearage amount of $38,019 was correct	Credit for periods when child lived with Sullivan should reduce arrears	Guidelines apply; Sullivan not primary caregiver during asserted periods; no deviation shown	Arrearage amount upheld; no explicit error in calculation
whether the court properly applied child-support guidelines and found no deviation	Disputed credit as deviation or miscalculation	Court acted within guidelines and properly declined deviation	Correct application; no abuse of discretion

Sloan v. Christianson, 2012 ME 72 (Me. 2012) (review of findings on appeal; evidence viewed in light most favorable to judgment)
Grant v. Hamm, 2012 ME 79 (Me. 2012) (best-interest standard; substantial deference to trial court)
Hatch v. Anderson, 2010 ME 94 (Me. 2010) (best interests and substantial evidence standard in family matters)
In re Alivia B., 2010 ME 112 (Me. 2010) (review of discretion in child-record access decisions)
Efstathiou v. Efstathiou, 2009 ME 107 (Me. 2009) (necessity of findings to support Rule 52(b) requests)
Fitzpatrick v. Fitzpatrick, 2006 ME 140 (Me. 2006) (explicit or implicit best-interest determinations may be made without formal explicit findings)
Charette v. Charette, 2013 ME 4 (Me. 2013) (weight given to witness credibility and court’s determinations on credibility)
Wong v. Hawk, 2012 ME 125 (Me. 2012) (crediting non-primary-care periods in calculating support)
Jabar v. Jabar, 2006 ME 74 (Me. 2006) (substantial evidence standard in child-support decisions)
Potila v. Nadeau, 2014 ME 5 (Me. 2014) (deviation considerations and guidelines adherence in support awards)
Bonville v. Bonville, 2006 ME 3 (Me. 2006) (trial court’s independent review of calculations when credit is disputed)