General19 Mar 2008 10:02 pm

A fellow Ole Miss Law School alumnus and divorce attorney in Memphis has posted an insightful article on his blog about client expectations when it comes to how a lawyer spends his or her time working on cases. The title of his post is “Lawyer Time vs Real People Time” and you can read it by clicking here. One point I would add to his excellent article is the influence of what I call “TV Law” on people’s expectations when it comes to real life lawyers and cases. In real life, cases NEVER progress at the pace depicted on TV. Even the best and most accurate legal shows on TV are totally unrealistic when it comes to the time consuming research and other “legal work,” etc. that goes on before a case actually winds up at trial. A typical contested divorce case in South Carolina takes at least a year from the time the complaint is filed until the divorce is granted.

The only legal TV show that has come even close to giving viewers a glimpse of what goes on “behind the scenes” in order to successfully prosecute a law suit was the show “Damages” which was on FX last fall. Of course, I’m not talking about all the illegal activity that all the lawyers engaged in on that show. I’m talking about the legitimate work that all lawyers have to do in order to get a case ready for trial, and this show gave you a glimpse of that.

So if you’re involved in a Family Court case and it seems like nothing is happening for weeks or maybe even months, you can rest assured that your lawyer is working on your case, and he or she is working at the pace the system is designed to handle.

General and Divorce15 Mar 2008 09:03 am

I suppose every attorney who practices Family Law has his or her own definition of what constitutes an “uncontested” divorce. To further complicate matters, clients usually have their own definition of “uncontested” when it comes to their particular marriage and its dissolution. In an ideal situation, a truly uncontested divorce in South Carolina is one where the parties have lived separate and apart for the statutory period of one year, and have worked out every issue ahead of time that would normally be decided by the court in a full-out contested divorce. This would include, but is not limited to, the division of marital property, spousal support, child support, child custody, and child visitation. None of these issues are contested. There is no discovery and there are no witnesses. And ideally, the non-complaining spouse represents himself or herself pro se, with his or her response to the complaint being an Affidavit of Consent. The agreement is presented to the court at the final hearing and there is no “trial” so-to-speak. The judge reviews the agreement to make sure it conforms to the law and is fair, and that the parties agree to its terms voluntarily. The terms of the agreement are incorporated into the divorce decree and the divorce is granted.

General and Divorce12 Jan 2008 07:09 pm

The following is an excellent article from Sean Stephen’s Oregon Divorce Blog:
Divorce is not easy. There are many pitfalls and traps awaiting parties that have not educated themselves about the process. People often make bad decisions under stress, or without the guidance of an experienced lawyer. Don’t be one of them. Divorce law isn’t rocket science, but it isn’t always intuitive. Avoid the following 10 divorce pitfalls to get a better result.

During your divorce, you should NOT:

1. Lie to your lawyer: We are here to help you. Your communication with us is privileged, meaning we can’t tell others about it, except in certain child abuse scenarios. The more we know, the more we can help. We need to know everything, the embarrassing, the ugly, and the secret. If you have a drug, alcohol, or gambling problem, tell us. You have two options: (1) Disclose and likely hear from your lawyer that your secret or problem is irrelevant to the court process, or (2) Fail to disclose and have your case hurt at trial because the other lawyer knows facts you haven’t told your lawyer.

2. Lie to the court: If you have a trial, the result is directly affected by your credibility. Judges are generally experts at determining who is telling the truth, and who is lying. Not only is lying to the court a crime, but your lawyer may have a duty to stop the proceeding and tell the court if he or she knows you are misrepresenting facts! If you have areas of your case that are sensitive, work with your lawyer on what you are going to say, but don’t misrepresent.

3. Involve the kids in the process: If your case involves a custody or parenting time dispute, nothing will draw the wrath of the court faster than involving your kids in the dispute. Don’t talk to them about the case. Don’t use them as pawns in the battle against your spouse. Don’t use them as your therapist, or treat them as your peers. Don’t put your spouse down in front of the kids. You are not only harming your case, you are harming your children.

4. Hide or fail to produce documents: You have an absolute right to see your spouse’s financial documents. Your spouse has an absolute right to see your financial documents. I have seen many cases that could have been simple turn complex and expensive when someone decides to not voluntarily produce records. The court can force you to produce records, and order that you pay your spouse’s lawyer fees incurred in getting the records. Good clients and good lawyers produce documents quickly and voluntarily. I had a case where we asked for some email records from the other side. They did not produce them, and when we filed a motion to compel their production, they tried to tell the court that they had been destroyed. The stunt seriously impacted the opposing lawyer’s credibility with the court.

5. Refuse to cooperate with a court appointed expert: In divorce and custody cases, experts called “custody evaluators” are routinely appointed to gather information about a family and make a recommendation regarding an appropriate parenting plan. If one is appointed in your case, cooperate. Be on time for appointments. Treat the expert with appropriate respect. Ignoring the requests of the evaluator can seriously harm your position and credibility with the court. An evaluator will likely make negative assumptions about you if you cannot comply with a court’s order to cooperate.

6. Settle without analyzing your case: Divorce can be unpleasant and emotionally painful. One reaction is to try to get it over quickly. Do not give into the urge to be done with the case before you have a full understanding of the assets and what a fair distribution looks like. You don’t want to be in a position where you are contemplating settlement and your spouse knows more about the assets than you. Prepare and go over a proposed distribution of assets and liabilities with your lawyer. Make sure you know the nature and extent of the assets, and get additional discovery if you don’t. Do not settle prematurely, before you know what is fair.

7. Fail to try to resolve the case outside of court: Don’t settle early without analysis, but also don’t fail to try to settle. Good lawyers and reasonable people settle most divorce cases without a trial. Many clients benefit from mediation, either through the county courthouse or through a private mediator. Our experience has been that many very difficult settle in mediation with the guidance of a trained expert mediator. You should always consult with your lawyer during the process to make sure you are getting a fair result. Settling also means you choose the outcome rather than have a judge impose an outcome on you. Parties that settle are generally happier long term, and have less ongoing conflict. Even if the other side is unreasonable, you should still make an offer to create a record of your position.

8. Take out your stress in unhealthy ways: This is the wrong time to up the drinking or other unhealthy behavior. Expect stress from the conflict and plan for it. Take out your stress in healthy ways, like at the gym, sports, or in talking to friends or a counselor. Don’t take it out on your children, or your body through unhealthy behaviors.

9. Be economically irrational in negotiations: At some point in every case it costs more to continue arguing than what is at stake. Approach your case with a business like mind. Are you really winning if you spend $1000 on lawyers to argue over a $50 lamp? Some (bad) lawyers insist on arguing about every point, without regard to cost. Every issue is a new battle front. A request to resolve one issue results in two more contested issues. In our opinion, these lawyers don’t serve their clients well. Pick your battles. If it costs $1000 to argue over something you can replace at Target for $20, buy a new one, and focus on what is really important.

10. Be your own lawyer if your case is contested and your spouse is represented: Many judges dislike unrepresented parties. Even experienced divorce lawyers hire experienced divorce lawyers for an objective opinion. Many unrepresented people who think they have a great case find out otherwise after a judge rules against them because they can’t tell the judge everything they want to because of the rules of evidence. If you disagree over property or custody, and your spouse has a lawyer, seek representation.

General and Divorce and Alimony and Child Support and Child Custody and Visitation and Family Court26 Aug 2007 08:26 am

The Family Court system in South Carolina was created by statute in 1976. The Family Court has exclusive jurisdiction over all matters involving domestic or family relationships and hears all cases concerning marriage, divorce, legal separation, custody, visitation rights, termination of parental rights, adoption, support, alimony, division of marital property and change of name. The Family Court also generally has exclusive jurisdiction over dependent or neglected children under eighteen years of age, and over minors under the age of seventeen alleged to be delinquent and to have violated any state law or municipal ordinance. However, most traffic and fish and game law violations committed by juveniles are triable in the summary courts. Juveniles charged with serious crimes may be tried as adults and transferred to Circuit Court. Family Court judges are elected for six year terms by the General Assembly. There are currently fifty-two judges in Family Court, selected by circuit seat. Generally, Family Court judges rotate from county to county within their home circuit, however, the Chief Justice may assign them to other circuits based on caseload needs.

-Adapted from the SC Judicial Department web site

General and Alimony25 Aug 2007 09:24 am

In the recent South Carolina Court of Appeals case of Kelley v. Kelley a wife was barred from collecting alimony even though the original divorce decree stipulated that the husband pay both alimony and child support. The original order of support and alimony was based on the wife having custody of the couple’s two boys. Within four years of the divorce the two boys had moved in with their father and the husband claims at that point he and wife orally agreed that he no longer owed her alimony, nor did he owe child support since the boys were living with him, and that she would not have to pay him any child support. That was in 1978. In 2001 the wife went to Family Court asking that husband be held in contempt for failing to pay alimony according to the previous court order. The husband answered and asserted the defenses of equitable estoppel and laches. (Laches is another equitable defense which the Court found applied in this case, but which is not discussed here.) The Family Court ruled in the husband’s favor finding that the wife’s claims were barred by equitable estoppel. The wife appealed the Family Court ruling to the South Carolina Court of Appeals. That Court affirmed the Family Court ruling, specifically stating that

… Wife’s conduct conveyed the impression that Husband was no longer obligated to pay alimony based on Husband’s understanding that Wife agreed to waive alimony in exchange for him having custody of the children and based on Wife’s failure to demand alimony from Husband in over twenty years. Further, Wife intended Husband to rely on the agreement that he not pay her alimony, so that he, in turn, would not pursue child support against her. Husband’s decision not to seek child support also shows he was justified in relying on the parties’ decision to mutually waive support obligations. Lastly, Husband changed his position in reliance on the agreement because if he had known he had a lingering support obligation, he would have sought to have his obligation reduced or eliminated.

Equitable Estoppel is a principal in equity that prevents a person from coming into court and asserting or denying a position that is at odds with that person’s past statements or actions when the contradictory position would be unfair to another person who has relied upon those past statements or actions and been prejudiced by that reliance. To put that rather convoluted definition in the context of this case, let’s say that

(A) = “You don’t owe me any alimony.”

(B) = “You owe me alimony.”

Equitable Estoppel says the wife can’t say things or act in a way that leads the husband to believe (A) and then come into court and claim the opposite (B) when husband has in fact believed (A), relied upon (A), and changed his position because of (A).

General and Divorce23 Aug 2007 08:36 am

This is an excerpt from an excellent article written by Charleston divorce lawyer, Melissa F. Brown.

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While every family is unique, with its own special areas of agreement and dispute, the processes involved in the resolution of family matters are often subdivided into identifiable categories within the Family Courts of South Carolina. This summary will examine the main stages of traditional Family Court cases. It is not intended to deal with every situation that may arise in matrimonial disputes, but rather, it is intended to give a general overview of the significant events that are often anticipated in a Family Court case. It will also discuss the manner in which this office approaches this sensitive area of negotiation and litigation.

When meeting with a potential client, an early question I pose is whether the client believes a possibility of reconciliation exists. Before I will initiate a suit, I seriously discuss and consider this question with the potential client. Only those clients who believe with a degree of certainty that their marital relationship will end should proceed in a divorce action. Divorce cases are devastating to the family, emotionally draining to all of the family members, and financially and emotionally expensive.

As a professional, I see a divorce as a matter of last resort. I often find clients are shocked by the many issues that are part of a divorce such as child custody, visitation, decision making rights, relocation, child support, alimony, property and debt division, tax matters, attorney fees, etc. My goal, therefore, is to examine whether other steps should be taken which might heal the relationship before an attempt to dissolve the marriage is initiated.

South Carolina has four fault grounds of divorce: adultery, physical cruelty, and habitual drunkenness or addiction to narcotic drugs. The fifth ground is considered no-fault and requires separation for a period of one year. In order to secure a divorce, the party who files must prove at least one of these grounds with legal evidence (for example: testimony, photographs, letters, hospital or physician records, reports from private investigators, etc.).

Unlike many states, there is not a provision in our laws for a “legal separation” in South Carolina. A couple is either married or not married. There is no other legal relationship. However, there is a step, which may be taken in the court– “An action for separate maintenance and support,” which resembles a legal separation. Generally, the same procedures outlined below will occur in a separate maintenance and support action. While, there are no clearly established grounds or reasons for a separate maintenance, one must generally show some cause why the marriage should be dissolved.

If circumstances are such that it is necessary to file suit, family law related matters are heard and determined in the Family Court of the State of South Carolina. Under the umbrella of “family law related matters” are divorce, actions for separate maintenance and support, child custody determination and modification, paternity identification, and actions related to alimony and support. We have Family Courts in each of our state’s 46 counties, and those counties are grouped together in Judicial Circuits.

In some states, a judge might hear many types of cases such as murders and contract disputes in addition to family law matters. In our State, we have the benefit of Family Court Judges who only perform Family Court work. This focus on matrimonial and domestic relations matters means that our judiciary is educated and experienced in the laws and the equities related to family matters, and they hear Family Court cases by choice rather than imposition.

The case must be initiated by a Summons and a Complaint. The Summons is the document that gives the other spouse notice that he or she will have 30 days to respond (by filing a document in the Court) to the allegations made in the document called a Complaint. The Complaint sets forth the factual and legal basis for seeking a divorce. I usually ask my clients to verify these claims under oath. A spouse’s responsive document is called an Answer or Answer and Counterclaim.

The Summons and Complaint, once approved by my client, are then filed in the Clerk of Courts Office in the County where the action takes place. The Court requires a $100.00 filing fee plus an additional $25.00 fee to file a motion. Upon filing, a Docket Number is assigned to that case; this number must be written on all pleadings and motions filed in the Court thereafter.

Next in the process is serving the other spouse with the Summons and Complaint. One spouse cannot simply hand a copy of the Summons and Complaint to the other spouse. Instead, these documents must be delivered by an independent third person. A private process server or a sheriff typically completes the act of Service on the other party.

Once a spouse is served, he or she has 30 days in which to respond to this complaint. This response is called an Answer or Answer and Counterclaim. The filing of an Answer and Counterclaim means that the opposing party is also asking for relief from the Family Court. The Counterclaim sets forth the opposing party’s version of the facts and law to defend against our lawsuit and may also ask for other relief from the Court. If that is the case, my client will then have 30 days to reply to the Answer and Counterclaim in a document called a Reply. This Reply sets forth my client’s factual and legal arguments as they apply to the Answer and Counterclaim.

The facts in a divorce document (Complaint, Answer, Reply and the like) must be as accurate as possible. Occasionally facts in a pleading will state “upon information and belief” which simply means that those facts were discovered from another source, but are believed to be true. If purposefully incorrect or untruthful statements are included in a pleading, the court will not look favorably upon the party who is making misrepresentations. Serious cases could result in perjury charges.

Once a divorce Complaint is filed with the Clerk of the Family Court, no final divorce can be granted in less than a period of three months. The exception to this general period is when a divorce is filed after the parties have been separated for more than one year and have reached an agreement. Then, the parties do not have to wait three months after filing to obtain a divorce.

General and Divorce23 Aug 2007 08:22 am

Michael Sherman posted this article on his excellent Family Law Blog. It is from divorceonline.com. This is a basic checklist of things to consider when you are contemplating a divorce. Discuss these issues with your attorney. The list is not meant to be exhaustive and your attorney may raise other issues not listed here, and which you may not have considered. That is why it’s usually a good idea to consult an attorney when you are facing a divorce or separation from your spouse.

1. Custodial arrangements for the children.
2. Visitation/parenting time.
3. Child support.
4. Medical, dental, hospital, pharmaceutical, and psychological expenses for the children.
5. COBRA or medical insurance for a former spouse for up to 3 years from the entry of the divorce judgment where applicable.
6. Income tax exemptions regarding the children — who will claim them.
7. Alimony/spousal support.
8. Property division.
9. Division of real estate, transfers, and deeds.
10. Making sure that all investments are covered including limited partnerships, stocks, bonds, and savings.
11. The handling of debts.
12. Pensions, IRA accounts, 401K transfers, Qualified Domestic Relations Orders.
13. Personal property including furniture, furnishings, art, and collectibles.
14. Motor vehicles, including trailers and boats.
15. Income taxes whether there can be joint filings and liabilities for payment of taxes.
16. Bankruptcy issues, protection in case one spouse does go bankrupt.
17. Proper security and protection regarding property division.
18. Clauses to hold the other spouse harmless and indemnification in case someone fails to live up to his or her obligations
19. How to handle the discovery of hidden assets.
20. Spouse abuse and restraining orders.
21. Restoration of a prior maiden name.
22. Life insurance policies as protection for child support payments, alimony/spousal support payments, and/or property payments in the event of death.
23. Attorney fees and/or mediator, accountant, and other expert fees and payment of same.
24. College education for children and/or spouse.
25. Provisions for review in certain circumstances such as with regard to child support and/or spousal support.
26. Clauses such as payment for summer camps and/or religious training and/or upbringing or other special situations involving children.