Richard Conway v. Amanda Orenberg

Summary

The Rhode Island Supreme Court reviews Richard Conway’s appeal from Family Court orders concerning primary placement of the parties’ children and child support. The Court vacates the portion of the placement order awarding primary placement to Amanda Orenberg because the Family Court made insufficient factual findings regarding the children’s best interests, affirms the child-support guideline worksheet, and holds that the challenge to the handwritten child-support order is moot. The case is remanded for further proceedings.

Holdings

1. The Family Court's placement order was vacated insofar as it awarded Orenberg primary placement because the record contained insufficient factual findings concerning the children's best interests to permit appellate review.
2. The child-support guideline worksheet constituted a valid order because Conway's attorney signed it, and the client is ordinarily bound by the acts of the attorney of record absent special circumstances.
3. The appeal from the handwritten order was moot because the Supreme Court affirmed the child-support guideline worksheet, which imposed the same $1,254 monthly child-support obligation and left no practical effect for a ruling on the overlapping child-support issue.

Questions Presented

1. Whether the Family Court could award Orenberg primary placement without sufficient factual findings concerning the children's best interests.
2. Whether the child-support guideline worksheet signed by both attorneys constituted a valid order binding on Conway despite his later objection to the child-support calculations.
3. Whether Conway's appeal from the handwritten order remained justiciable after the Supreme Court affirmed the child-support guideline worksheet.

Disposition

reversed_and_remanded