A.M.L. v. J.W.L.
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The "Child Custody, Support and Property Settlement Agreement" between A.M.L. and J.W.L., incorporated into their February 2002 "Final Judgment of Divorce," provided that they would share "joint legal custody" of their four daughters, with A.M.L. having "primary physical custody" and J.W.L. having frequent visitation. The Agreement also provided for, inter alia, child support, medical expenses and reimbursement, college expenses, and life insurance naming the children as beneficiaries. In the following years, J.W.L. became effectively estranged from his two oldest daughters, and ceased overnight and weekend visitation with both. In 2008, A.M.L. filed a "Petition for Modification and/or Clarification of Final Judgment of Divorce" and J.W.L. responded with a "Counterclaim for Modification of Custody and Other Relief." A.M.L.'s Petition requested full "legal and physical custody" of the children, an increase in child support, clarification of several Agreement provisions, contempt orders against J.W.L. for his alleged failure to comply with various Agreement provisions, and attorney fees. J.W.L.'s Counterclaim sought "full legal and physical custody" of their two youngest daughters, with attending modifications of Agreement provisions regarding child support, medical expenses, and college expenses. Following trial, the Chancery Court of Madison County, Mississippi, entered its "Opinion and Judgment on Petition for Modification and/or Clarification of Final Judgment of Divorce." Regarding child custody, the chancellor found a "material change in circumstances . . . which warrant[ed] modification of custody and the transfer of primary physical and legal custody of [the three youngest children] to [J.W.L.,]"
based upon conduct of the children which was attributed to A.M.L. "impos[ing] little or no discipline." Yet the court delayed ordering custody modification, holding such ruling in abeyance, "subject to the parties adhering to" several court-imposed conditions. A.M.L. retained physical custody of the children. The "Opinion and Judgment" also modified J.W.L.'s child-support and college-expense obligations, and denied A.M.L.'s request for attorney fees. Following the denial of post-trial motions filed by A.M.L. and J.W.L. with respect to the rulings challenged on appeal, A.M.L. filed "Notice of Appeal" and J.W.L. filed "Notice of Cross-Appeal." Based upon this analysis, the Supreme Court affirmed the chancellor's findings: (1) that A.M.L. had not "actively engaged" in alienation efforts; (2) that there would be no "upward retroactive modification" in J.W.L.'s child-support obligations for C.D., W.X., and Y.Z.; (3) that J.W.L. did not act in contempt in failing to comply with the thirty-day, noncoveredmedical-and-dental-expenses reimbursement provision of the Agreement; (4) that J.W.L. did not act in contempt of the "written proof" requirement in the life-insurance provision of the Agreement; and (5) that A.M.L.'s request for contempt-related attorney fees should be denied. The Supreme Court reversed the chancellor's findings: (1) of child-custody modification, as there was no "material change in circumstances" in the custodial home and no "Albright" analysis at the time of the initial ruling; (2) of retroactively terminating J.W.L.'s child support obligations for A.B.; (3) of applying "Hambrick" to C.D. and, based thereon, limiting J.W.L.'s college-expense obligation for her; and (4) of denying A.M.L.'s modification-related attorney fees for failure to "timely introduce any evidence" thereon.
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