HomeMy WebLinkAbout94-0006 SupportWENDY HICKMAN,
Plaintiff
VS.
MAHLON Z. ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0006 SUPPORT
DOMESTIC RELATIONS SECTION
:
: DR,q 22,118
MAHLON Z. ADAMS,
Plaintiff
VS.
WENDY HICKMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0391 SUPPORT
:
: DOMESTIC RELATIONS SECTION
:
: DR//22,600
MEMORANDUM OPINION AND ORDER
ORDER
AND NOW, this day of January, 1998, following hearing in this case,
our previous orders in this matter are VACATED. The order of court in and for the County of
Contra Costs, State of California is herewith registered and arrearages, according to the payment
record of the case are herewith set in the amount of $20,150.93.
With respect to said amount owed at 6 Support of 1994, the defendant/plaintiff, Mahlon
Z. Adams, shall be entitled to a credit of any amounts which are due and which remain unpaid in
the support action docketed to 391 Support of 1994, which amounts have been determined to be
$3,923.35.
BY THE COURT,
WENDY HICKMAN, Plaintiff
VS.
MAHLON Z. ADAMS, Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0006 SUPPORT
DOMESTIC RELATIONS SECTION
DR# 22,118
MAHLON Z. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: 94-0391 SUPPORT
VS.
: DOMESTIC RELATIONS SECTION
WENDY HICKMAN, :
Defendam : DR//22,600
MEMORANDUM OPINION AND ORDER
On April 26, 1996, we filed an opinion in this longstanding support dispute. Therein, we
set out the history of this case, noting that it has its origins in a support order dated September
17, 1981, in the Court of Contra Costa, California. It is this order which Wendy Hickman as
plaintiff seeks to register in this county. As we previously noted, over the years and despite
changed circumstances, existing support orders were not amended. We therefore attempted to
reconstruct the financial histories of the parties giving credits against the Contra Costa order as
we thought appropriate.
An appeal of our order was quashed by the Superior Court and the matter was remanded
to us and eventually to the Domestic Relations Office to calculate certain other credits. The
matter has now found its way back to the trial court. The obligee of the Contra Costa County
order, Wendy Hickman, takes the position that we erred in failing to give full faith and credit to
the California order, in altering the time periods of Mr. Adams' obligation to pay support and
6 SUPPORT 1994
391 SUPPORT 1994
that the calculation of credits on the part of the Domestic Relations Office were in error. We are
now persuaded that Ms. Hickman's position is fundamentally correct.
This matter is-governed by the provisions of Chapter 76 of Title 23 of our Pennsylvania
Statutes. 23 Pa.C.S.A. 7601 et seq. These provisions of the law were enacted on April 4, 1996.
Though this protracted registration proceeding began before that, the case having been docketed
in 1994, we are entirely satisfied that, provided the plaintiff complies with the current
requirements for registration, her case should not be judged in light of an outmoded statute.
The law, as it currently exists, provides for the registration of foreign orders. It requires
that we give them full faith and credit but, contrary to Ms. Hickman's rather narrow
understanding of that term, the order need not necessarily be accepted at face value. There is a
procedure to contest the validity or enforcement of a registered order. That is precisely what Mr.
Adams has sought to do. The defenses to the registration of a foreign order are set out in 23
Pa.C.S.A. 7607 which reads as follows:
7607. Contest of registration or enforcement
(a) Defenses. - A party contesting the validity or
enforcement of a registered order or seeking to
vacate the registration has the burden of proving
any of the following defenses:
(1) The issuing tribunal lacked personal
jurisdiction over the contesting party.
(2) The order was obtained by fraud.
(3) The order has been vacated, suspended or
modified by a later order.
(4) The issuing tribunal has stayed the order
pending appeal.
(5) There is a defense under the law of this State
2
6 SUPPORT 1994
391 SUPPORT 1994
to the remedy sought.
(6) Full or partial payment has been made.
(7) The statute of limitation under section 7604
(relating to choice of law) precludes enforcement of
some or all of the arrearage.
23 Pa.C.S.A. 7607(a). We are satisfied that, with the possible exception of 7607(a)(5), Mr.
Adams has failed to prove the applicability of any of these provisions.
By noting a "defense under the law of this state" we make reference to Ms. Hickman's
claim for interest under the California order. She has, in fact, filed two different orders in this
case, one with interest from the 1980s and one without. We do not believe that it is appropriate
to register the California order with interest.
As our opinion of April 26, 1996, notes, it is unclear as to whether or not the interest
portion of the California order applies to support arrearages or to other amounts which are due in
the order. Moreover, we know of no provision under Pennsylvania law for the assessment of
compounding interest in support matters. Instead, we note that the law provides that the "court
may impose a penalty of not more than 10% on any amount in arrears for 30 days or more if the
court determines that the arrearage was willful." 23 Pa.C.S.A. 4348(c). In this case, a ten
percent penalty on the amount of the arrears would not begin to approximate the more than
doubling of the arrearages which occurs by compounding interest.
In registering the California order, we will credit Mr. Adams with those amounts due and
unpaid at the support case docketed to 94-0391. The arrearage in this case, shortly after its
docketing, was adjusted to $333.60. Thereafter, Ms. Hickman made regular payments in the
6 SUPPORT 1994
391 SUPPORT 1994
amount of $398.75. In the course of her attempts to register the California order, her obligations
to Mr. Adams at 391 Support 1994 were held in abeyance. Pursuant to our order of February 2,
1996, which we now acknowledge was improvidently entered, Ms. Hickman was credited with
her entire arrearage of $2,727.10. This arrearage figure must now be reinstated. The order was
terminated effective in May of 1996 because the child, Sarah, had attained her majority.
Arrearages in the amount of $1,196.25 had accrued between February and May. Thus, the total
accrued arrearages on this order as of May 1, 1996, were $3,923.35.
ORDER
AND NOW, this z :~ '~' day of January, 1998, following hearing in this case,
our previous orders in this matter are VACATED. The order of court in and for the County of
Contra Costs, State of California is herewith registered and arrearages, according to the payment
record of the case are herewith set in the amount of $20,150.93.
With respect to said amount owed at 6 Support of 1994, the defendant/plaintiff, Mahlon
Z. Adams, shall be entitled to a credit of any amounts which are due and which remain unpaid in
the support action docketed to 391 Support of 1994, which amounts have been determined to be
$3,923.35.
BY THE COURT,
v~. Hess, J.