Ieasha Hipps v. Ruben Cabrera

Summary

The District of Columbia Court of Appeals reviewed challenges to custody-related rulings, including the denial of Rule 11 sanctions, discovery and contempt issues, evidentiary rulings, and relinquishment of continuing jurisdiction. The court affirmed the denial of sanctions and the trial court’s decision to relinquish jurisdiction under the UCCJEA’s inconvenient-forum and continuing-jurisdiction provisions. It vacated other challenged rulings for further proceedings.

Holdings

1. The denial of Rule 11 sanctions was affirmed because the mother's Sprint records did not establish by clear and convincing evidence that the father manufactured the text messages or committed perjury; the messages could have been sent through another device or application.
2. The trial court properly relinquished jurisdiction over the custody orders because the children and the father no longer had a significant connection with the District and substantial evidence concerning the children's care, protection, training, and personal relationships was no longer available there; the decision was also within the trial court's broad discretion under the UCCJEA's inconvenient-forum provision.
3. After deciding to relinquish jurisdiction, the trial court should not have denied the pending contempt and discovery-related motions; it should have stayed those matters pending commencement of a custody proceeding in New York and deferred to the New York court to address still-pending enforcement and discovery issues.

Questions Presented

1. Whether the trial court properly denied Rule 11 sanctions based on the mother's allegation that the father submitted fabricated text messages and committed perjury.
2. Whether the trial court properly relinquished continuing jurisdiction over the custody orders under the Uniform Child Custody Jurisdiction and Enforcement Act's inconvenient-forum and significant-connection provisions.
3. Whether the trial court erred by ruling on, rather than staying or deferring, the mother's pending contempt and discovery-related motions after deciding to relinquish jurisdiction.
4. Whether the trial judge should be disqualified from further proceedings because of alleged bias favoring the father.

Disposition

other