Dalton v. DaltonAnnotate this Case
After a hearing, the trial court granted Timothy Dalton and Sarah Dalton a divorce and awarded parental rights and responsibilities and primary residence of the children to Timothy. In the months following the divorce judgment, Sarah sought to collaterally attack the judgment by filing numerous post-judgment motions in an effort to modify the visitation and supervision arrangement in the judgment. After a hearing, the court denied or declared moot all of Sarah’s motions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in its evidentiary rulings during the hearing on Sarah’s post-judgment motions; (2) the trial court did not abuse its discretion in denying Sarah’s motion for additional findings of fact and conclusions of law; and (3) the trial judge did not err in failing to sua sponte recuse himself from this matter.