SNYDER v. LEAGUE

Citations

• 2024 OK CIV APP 21

Syllabus

¶1 In this post-paternity action, Appellant/Plaintiff, James Steven Snyder (Father), appeals from the trial court's journal entry denying Father's motion for new trial or in the alternative motion to reconsider. Father requested the trial court to reconsider its judgment modifying the court's emergency custody and visitation order and awarding Appellee/Defendant, Erica Lynn League (Mother), sole custody of the parties' minor child and reinstating Father's previous visitation with a few modifications. Father contends the trial court abused its discretion when it denied his motion for a new trial because the court should have entered a judgment granting Father equal-time with the minor child and the court should have issued findings of fact and conclusions of law as mandated by 43 O.S. 2021 §110.1 . Father also contends the trial court should have granted a new trial because it erroneously failed to apply 43 O.S. 2021 §112.2 (B)(3) and award Father custody due to Mother's substance abuse. Father also challenges the trial court's evidentiary rulings when it excluded Father's evidence of Mother's substance abuse treatment and when it admitted certain exhibits and hearsay evidence over Father's objection. We hold §110.1 is inapplicable to this paternity proceeding. We further hold the trial court consider §112.2(B)(3) when it awarded Mother sole custody of the child and reinstated Father's previously awarded visitation. We finally hold Father failed to show he was prejudiced by the trial court's evidentiary rulings and that such rulings did not amount to reversible error. Because we hold in this matter, we cannot find the trial court abused its discretion when it denied Father's motion for a new trial. The trial court's order and the underlying custody judgment are affirmed.