Scurlock v. Johnson CA2/4
B332474
| Cal. Ct. App. | Aug 4, 2025Background
- The parties, Reginald Scurlock (father) and Roman James, formerly Shannon Johnson (mother), have a child, A.J.; the mother receives CalWORKs public assistance.
- In 2019, the parents stipulated to a zero child support order.
- In 2022, the Los Angeles County Child Support Services Department (CSSD) sought to modify the order, citing mother's public assistance status as a material change.
- After hearings in 2022-2023, the trial court ordered father to pay $1,144/month in support, based on the statewide guideline formula and the parties’ 2022 incomes (mother: $17,112; father: $191,586), with 50/50 custody.
- On appeal, father (Scurlock) claimed error because evidence was not properly admitted, and his right to cross-examine mother was denied; appellate court affirmed the trial court’s order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was evidence properly admitted? | No evidence/exhibits were admitted or authenticated. | Evidence was properly submitted; father mischaracterizes the record. | Evidence was properly considered; appeal forfeited by incomplete record. |
| Was right to cross-examine denied? | Father was denied ability to cross-examine mother on her income. | Court had discretion, and no prejudice shown by denial. | Right not violated; no prejudice or material harm from limits on cross-examination. |
| Sufficient evidence of income/support? | Argued no evidence supported the child support calculation. | Documented income/expenses were provided; guideline formula applied. | Substantial evidence supports trial court’s calculation. |
| Appellate record and briefing requirements | Claims case not fully presented. | Father omitted necessary record evidence and legal authorities. | Appeal forfeited for failing to provide an adequate record and cogent argument. |
Key Cases Cited
- Jameson v. Desta, 5 Cal.5th 594 (appellate burden for sufficient record and error preservation)
- In re Marriage of Macilwaine, 26 Cal.App.5th 514 (application and presumption of guideline child support)
- County of Los Angeles v. Christopher W., 41 Cal.App.5th 827 (public policy for child support enforcement)
- In re Marriage of Rodriguez, 23 Cal.App.5th 625 (standard of review for child support modification)
- In re Marriage of Calcaterra & Badakhsh, 132 Cal.App.4th 28 (acceptable forms of income evidence at modification hearings)