Lane v. Lane
254 So. 3d 570 (2018)
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Rule of Law:
When divorced parents with shared parental responsibility cannot agree on a major decision affecting their child's welfare, such as education, the trial court must resolve the impasse by determining the child's best interests, and this determination is reviewed for abuse of discretion.
Facts:
- Susan Lane (the "mother") and Keith Lane (the "father") were divorced by Final Judgment of Dissolution of Marriage on October 13, 2015, establishing shared parental responsibility for their two minor children, P.L. (born 2006) and M.L. (born 2007).
- For the 2017-2018 academic year, P.L. attended sixth grade at Palmetto Middle School and M.L. attended fifth grade at Palmetto Elementary School, which were public schools in the mother's district.
- The mother wished for both children to attend Palmetto Middle School for the 2018-2019 academic year, but she was moving and would no longer reside in that school district.
- The father desired for the children to attend Westminster Christian School ("Westminster"), a private school, for the 2018-2019 academic year and volunteered to be solely responsible for all associated costs.
- The father took their son, P.L., to Westminster for an admission eligibility test without the mother's prior knowledge or consent.
- The mother's primary objection to Westminster was on educational grounds, stating she did not believe a Christian-based education system with daily Bible study was important for the children's education, but clarified she was not necessarily opposed to any church-associated school.
Procedural Posture:
- The parties were divorced by Final Judgment of Dissolution of Marriage on October 13, 2015, in the Circuit Court for Miami-Dade County, which established shared parental responsibility for their minor children.
- On March 20, 2017, Susan Lane (mother) filed a Verified Motion for Contempt and to Compel Father to Comply with Shared Parental Responsibility in the Circuit Court for Miami-Dade County, arguing Keith Lane (father) violated shared parental responsibility by taking their son to Westminster without her consent for testing.
- On September 14, 2017, Keith Lane (father) filed an Amended Motion to Authorize Children’s Enrollment at Westminster Christian School at Father’s Sole Cost in the Circuit Court for Miami-Dade County, alleging Susan Lane refused to discuss enrollment.
- On October 11, 2017, the Circuit Court for Miami-Dade County held a hearing on both motions, at which both the mother and father testified.
- On October 18, 2017, the Circuit Court for Miami-Dade County (trial court) entered an Order granting the father's Motion to Authorize Enrollment, finding it in the children's best interest to enroll at Westminster, authorizing applications and enrollment, making the father solely responsible for costs, and directing the mother to cooperate. The Order also denied the mother's Motion for Contempt.
- Susan Lane (appellant) appealed the trial court's non-final order to the Third District Court of Appeal of Florida.
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Issue:
Does a trial court abuse its discretion by authorizing one parent to enroll children in a private school and denying a motion for contempt, where parents with shared parental responsibility disagree on educational decisions and the court finds the enrollment to be in the children's best interest?
Opinions:
Majority - LAGOA, J.
No, the trial court did not abuse its discretion by authorizing the father to enroll the children in Westminster Christian School and denying the mother's motion for contempt. When parents sharing parental responsibility cannot agree on a major decision like education, the trial court must resolve the impasse by determining the child's best interests. This court reviews such determinations for an abuse of discretion. The court distinguished Eisele v. Eisele, which involved a 20-month prospective analysis for homeschooling, finding that the 10-month timeframe for an application-based private school enrollment, with an impending deadline, was not an abuse of discretion. The court found sufficient competent, substantial evidence to support the trial court's finding that the father had the financial ability to pay for Westminster, as he testified to securing a loan and his ability to pay, which was unrebutted. The court noted that unlike Herman v. Herman, the trial court was not ordering a parent to pay for private school, but rather the father was volunteering to pay. The court also determined that the mother's objection to Westminster was primarily educational, not based on a conflict with her religious beliefs, and the order to cooperate only applied to the application and enrollment process, not to enforcing the father's religious beliefs. Finally, the court affirmed the denial of the motion for contempt, stating that no case law indicates that taking a child for academic testing, without unilaterally withdrawing or enrolling them in a new school, constitutes a violation of shared parental responsibility, and a trial court is not required to find a person in contempt.
Analysis:
This case clarifies the broad discretion afforded to trial courts in Florida when resolving impasses between parents with shared parental responsibility regarding a child's education. It affirms that a prospective 'best interest' analysis is permissible within reasonable timeframes, especially when application processes and deadlines are involved. The decision also differentiates between a court ordering a parent to contribute to private school expenses (requiring specific financial findings) and a parent voluntarily assuming such costs (where the focus is on the parent's actual financial wherewithal and the child's best interest). Moreover, it sets a precedent that merely taking a child for an academic admission test does not, by itself, amount to a contemptuous violation of shared parental responsibility.
