In re Marriage of Hayden

Facts

This case involves the dissolution of the marriage between Laura Hayden and David P. Hayden Jr., with a focus on the allocation of parental responsibilities and child support for their son, J.H. The couple married in 2018 and later had their son, J.H., born in December that year. Laura had also a son from a previous relationship, Z.R., who lived with them until their separation in January 2021, when Laura filed a petition for dissolution citing irreconcilable differences. Throughout the litigation, issues arose regarding allegations of inappropriate behavior by Z.R. towards J.H., prompting the court to intervene and appoint a guardian ad litem to ensure J.H.'s safety.

Issue

The primary issues on appeal were whether the trial court erred in its allocation of parental responsibilities, the imposition of supervised parenting time for Laura, the ruling on child support, and whether the decisions made were in J.H.'s best interest considering the allegations and living conditions of both parents.

Holding

The appellate court affirmed the trial court's judgment. It found that Laura had forfeited several claims due to an incomplete record and lack of merit in the arguments presented, and implicitly supported the trial court's findings regarding the living conditions and the well-being of J.H. since living with David.

Reasoning

The court noted that many of Laura's arguments were not adequately supported by the record; thus, they could not be evaluated effectively. The trial court had determined that Laura's failure to keep J.H. and Z.R. apart jeopardized J.H.'s safety. Testimonies from the guardian ad litem and David indicated significant improvements in J.H.'s well-being while in David's care. Laura's claims about miscalculated child support and allegations of improper conduct by the guardian ad litem were rejected, citing procedural missteps and a presumption of correctness due to the incomplete record. Moreover, the court emphasized the obligation to ensure J.H's safety, consequently finding Laura's parenting time should be supervised. Overall, the appellate court placed trust in the trial court's assessment of the best interests of J.H., leading to the rejection of Laura's appeal and the affirmation of the custody and support decisions.