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660 So. 2d 72

660 So.2d 72

95 La.App.4Cir. 573

Bruscato v. Avant

Louisiana Court of Appeal

Decided July 26, 1995

Louisiana Court of Appeal · decided 1995-07-26

Cited by 1 later decisions — most recently October 2002

1 state decisions

Relies on 643 So. 2d 743 - State in Interest of AC

Good law ✅— No negative treatment on recordhow we know

Decided 1995-07-26

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[ iMURRAY, Judge,

¶1dissents.

¶2I respectfully dissent.

¶3The trial court correctly concluded that the statutes at issue established “new rules, rights and duties specifically relating to relief from family violence that occurs when the victimized family is divorced or separated.” Because of this the court found that the statutes were substantive, and refused to apply them retroactively to the retrial of this case.

¶4If this Act is applied retroactively Mr. Bruscato will lose custody of his child as well as his right to unsupervised visitation. Even *76his right to supervised visitation with his child will be conditioned upon his participation and completion of a treatment program.

¶5The Louisiana Supreme Court has held that the parent’s right to a family relationship with his or her child is an interest that far surpasses any property rights. State In Interest of A.C., 643 So.2d 743, 748 (La.1994). The statutes at issue change the substantive law with regard to that right. They are not merely procedural.

¶6The Act creates an irrebuttable presumption — a parent who has a history of family violence is unfit to have joint or sole custody or unsupervised visitation. The consequence of that presumption is to deprive the perpetrating parent of the right to a family relationship with his or her child. The parent cannot show that, despite the history, he or she is fit. The presumption is not rebuttable in the usual sense. The statute simply provides that the result of the presumption, the restriction of the parent’s relationship with the child, may be overcome when it is shown, by a preponderance of the evidence, that the perpetrating parent has complied with certain requirements and that particular circumstances exist.

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