# Petition for Writ of Certiorari — Burk v. Burk

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition for Writ of Certiorari
- **Published:** January 1, 1990
- **Citation:** 498 U.S. 816

## Text

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IN THE |

SUPREME COURT OF THE UNITED STATES

October Term, 1989

J. Robert Burk, Jr.,
Petitioner,

Vv.

Patricia A. Burk,

Respondent.

PETITION FOR WRIT OF CERTIORARI TO THE
SUPREME COURT OF NEW HAMPSHIRE

J. Robert Burk, Jr., Pro Se
20 Ledgewood Hills Drive
Apartment No. 207

Nashua, N. H. 03062

(603) 881-9617

May 25, 1990

QUESTIONS PRESENTED

Whether the New Hampshire Supreme Court
contravened Petitioner's right to due
process of law under the Fourteenth
Amendment to the United States Constitution
by summarily determining on the merits
questions involving substantial liberty
interests in custody of minor children

and property distribution, where Petitioner
had claimed that the evidence at trial

was insufficient to support challenged
portions of a divorce decree, and no

State appellate court reviewed the

record of proceedings below.

Whether Petitioner was denied due process
of law by having the merits of his divorce
determined by a mere attorney, not a
judicial officer as defined by State
law, where no judicial officer ever

heard or reviewed disputed issues de

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United States v. Nobles,
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477 U.S. 667 (1980) ..........4215
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418 U.S. 683 (1974) ........ 19, 20

Superior Court, 831 F.2d 362
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United States Statutes,
28 U.S.C. SS 1257 (3) and 2101 (c) and

Revised Rules of the Supreme Court
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TREATISE:

R. Wiebusch, 5 NEW HAMPSHIRE PRACTICE:
CIVIL PRACTICE AND PROCEDURE, Ch. 39
(eauity, i366) Ceume. i989) « « « « « « AQ

IN THE
SUPREME COURT OF THE UNITED STATES

October Term, 1989

No.
J. Robert Burk, Jr.,
..

Patricia A. Burk

PETITION FOR WRIT OF CERTIORARI TO THE
SUPREME COURT OF NEW HAMPSHIRE

Petitioner J. Robert Burk, Jr., Pro Se,
respectfully prays that a writ of certiorari
issue to review the judgment of the New
Hampshire Supreme Court entered in the
above-entitled cause on January 9, 1990.
This Order is reproduced as Appendix I,

annexed hereto.

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OPINION BELOW

The one-page order challenged herein
was issued on January 9, 1990 as a "summary
affirmance" without opinion, and without
review of the record, "in accordance with
(N.H. Supreme Court] Rule 25(1)(a),"_ see,
Appendix I, annexed hereto, withno hearing.

Petitioner moved for reconsideration,
citing the constitutional violation of
determining sufficiency of the evidence
questions "summarily" without any review

of the record. See, Bundy v. Wilson, 815

F.2d 125 (lst Cir. 1987) (due process for-
bids such determinations when substantial
liberty interests are at stake). Petitioner's
motion for reconsideration was timely filed.
The Supreme Court of New Hampshire
denied the motion for reconsideration
without hearing or opinion in an Order

dated February 27, 1990. See, Appendix II,

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annexed hereto.

Neither order was published in any

form.

JURISDICTION

This Petition is timely filed.

The jurisdiction of this Court is
invoked pursuant to 28 U.S.C. §§ 1257(3)
and 2101(c), and Rules 20.2 and 28.2,
Rules of the Supreme Court of the United

States.

CONSTITUTIONAL PROVISIONS

This Petition involves claims arising
under the Due Process and Equal Protection
Clauses of the Fourteenth Amendment to the

United States Constitution, which prohibit

_deprivations of liberty or property without

due process of law and the equal protection

of the laws.

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STATEMENT OF THE CASE

The basic facts and procedural history
of this case, necessary for a determination
of the questions presented in this Petition,
are not in dispute.

Petitioner filed for divorce in the
New Hampshire Superior Court, sitting in
Hillsborough County, on November 23, 1987,
case number 87-M-2028.

Numerous issues arcse as to custody
of and visitation with the parties' three
minor children, and with respect to division
of the parties' marital estate.

Petitioner demanded hearing, or re-
hearing de novo on disputed issues by a
regular justice of the Superior Court,
duly commissioned under State law as a

judicial officer. His repeated motions

in this regard were denied by the Superior

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Court, and not heard by the Supreme Court
of New Hampshire. See, Order of "summary
affirmance," Appendix I, in New Hampshire
Supreme Court case numbe. 89-482.

Among the issues raised by Petitioner
in his State Notice of Appeal in No. 89-
482, was the denial of access to the
Guardian Ad Litem's file for effective
trial preparation and preparation for
cross-examination, and the provision of
the final decree requiring a 73 % reduction
in custody/visitation time in the event
Respondent moved out of the State of New
Hampshire, to Colorado, which the decree
allowed her to do at her whim. These
issues were preserved in the Superior Court
by timely objection, motion, or motion for
reconsideration of the decree under State
practice.

When the New Hampshire Supreme Court
summarily affirmed the decree, overruling

Petitioner's sufficiency of the evidence

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challenges thereto, Petitioner filed a
timely motion for reconsideration raising
the due process issue under the Fourteenth
amendment. The motion was dated January
16, 1990.

The only hearing Petitioner was ever
afforded in the State courts was before a
marital master who was as a matter of State
law not a judicial officer, and was, rather,
merely a private attorney sitting for the
day, "({e]ffectively...[as] a de facto judge."

Cornforth v. Cornforth, 123 N.H. 61, 63,

455 A.2d 1049 (1983). This constitutional
grievance of Petitioner's was ignored by
both the Superior and Supreme Courts of

New Hampshire. The Superior Courts of the
State are so backlogged that were a trial
judge to be assigned to hear or even review
the transcriptural record of divorce cases,
virtually no other business could be con-

ducted in the courts. This explains, but

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does not justify, the jurisdictional and

hence due process defects in the State
system which allows determination of cases
by non-judges with no judicial review in
either the Superior or Supreme Courts,
contrary to the hearing requirement of the
Fourteenth Amendment.

The Superior Court refused Petitioner's
timely motions for production of the
transcriptural record of proceedings before
the master, for review by a Justice, and
the Supreme Court denied Petitioner's
request for requistion of the transcript
of Superior Court proceedings for review
by the Supreme Court in connection with
the notice of appeal in No. 89-482.

Petitioner's motion for reconsideration
of the judgment of the New Hampshire
Supreme Court in this case was denied
by that Court in its Order dated February
27, 1990. See, Appendix II. This timely

Petition follows.

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REASONS FOR ALLOWANCE OF THE WRIT

The New Hampshire Supreme Court has decided
important questions of federal law which have
not been, but should be, settled by this

Court, and has decided federal questions in

a way that conflicts with applicable decisions
of this Court and of the United States Court
of Appeals for the First Circuit. Rule
10.1(b) & (c), Rules of the Supreme Court

of the United States (eff. January 1, 1990).

I. THE DECISION OF THE SUPREME COURT
OF NEW HAMPSHIRE TO SUMMARILY
AFFIRM PETITIONER'S SUFFICIENCY OF
THE EVIDENCE QUESTIONS, IN HIS
ONLY APPEAL ALLOWED AS OF RIGHT
UNDER STATE LAW, WITHOUT REVIEWING
THE TRIAL RECORD, CONFLICTED WITH
THE DECISION OF THE UNITED STATES
COURT OF APPEALS FOR THE FIRST
CIRCUIT IN BUNDY V. WILSON, 815
F.2d 125 (lst Cir. 1987) AND CASES
OF THIS COURT COLLECTED THEREIN,
AND OFFENDED THE DUE PROCESS CLAUSE
OF THE FOURTEENTH AMENDMENT WHERE
SUBSTANTIAL LIBERTY AND PROPERTY
INTERESTS WERE AT STAKE.

Petitioner had appealed to the New Hamp-

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shire Supreme Court that the evidence at
trial was insufficient as a matter of law
to support the decree in this case. The
State Court summarily affirmed the decision
below in accordance with Rule 25(1) (a),
N. H. Supreme Court Rules Annotated, which
allows such a disposition, even where, as
here, the trial record was not requisitioned
by the State Supreme Court, nor reviewed
by it in any fashion.

The United States Court of Appeals for

the First Circuit ruled in Bundy v. Wilson,

815 F.2d 125 (lst Cir. 1987) that where
substantial liberty interests were at

stake, as in felony appeals, the New Hamp-
shire Supreme Court could not enforce

its Rule 25 in such a manner as to determine
sufficiency of the evidence questions without
some review of the evidence at trial.

In Your Petitioner's case, substantial

liberty interests in custody of and visitation

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with his minor children were at stake,

along with substantial property interests

in tens of thousands of dollars of marital
assets. It is beyond dispute that the

Due Process Clause of the Fourteenth Amend-
ment protects both "liberty" and "property."

Board of Regents v. Roth, 408 U.S. 564 (1972).

The First Circuit concluded in Bundy
that what process that was due litigants
in the New Hampshire Supreme Court included
actual review of a trial record before
summary disposition could be made of
questions implicating the sufficiency of -
the evidence at trial. The Court of Appeals
holding was squarely on due process grounds,
emphasizing that an appeal to the New Hamp-
shire Supreme Court is a litigant's one and
only chance for review in New Hampshire,
there being no intermediate court of appeals
in the State system.

Your Petitioner's appeal to the New

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Hampshire Supreme Court was indeed his only
available judicial review of a trial
master's determination of his divorce case.
Due process required that the New Hampshire
Supreme Court not summarily affirm the
challenged portions of the decree without
some review of the evidence to support it.
This obvious deprivation of Federal
due process is a special and important
reason for this Court to grant the writ

in this case.

II. PETITIONER WAS DENIED FOURTEENTH
AMENDMENT DUE PROCESS BY HAVING
THE MERITS OF HIS DIVORCE DECIDED
BY A MERE ATTORNEY-—NOT A JUDICIAL
OFFICER AS DEFINED BY STATE LAW—
WHERE NO JUDICIAL OFFICER EVER
HEARD OR REVIEWED DISPUTED ISSUES
DE NOVO OR REVIEWED ANY RECORD
OF THE TRIAL PROCEEDINGS.

Another patent defect in the State pro-
ceeedings, of Constitutional dimension, was

the failure and refusal of the State to

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afford Your Petitioner any hearing by a
judicial officer prior to the determination
of the merits of his divorce case.

A "judicial officer" in New Hampshire is
one nominated and appointed by the Governor
and Executive Council pursuant to Part II,
Articles 46 & 47 of the New Hampshire

Constitution. Opinion of the Justices,

128 N.H. 17, 19, 509 A.2d 746 (1986).

The private attorney who sat as a "master"
in this case was "not so appointed, tenured,
Or empowered" as a “judicial officer" as

a matter of law. Id., at 20. He lacked the
"necessary characteristic of a judicial
officer [,namely] the authority to render
judgment to determine issues that are
properly raised before the judicial branch,"

id., at 19, citing Rhode Island v. Massachu-

setts, 37 U.S. (12 Pet.) 657, 718 (1838)
and N.H. Constitution, Part I, Art. 37 and

Part II, Art. 72-a. Accordingly, this master

had no jurisdiction, "that final authority,"

Opinion of the Justices, supra, 128 N.H.,

at 19, to determine the issues in Petitioner's
divorce case. Ibid, citing R. Wiebusch, 5
NEW HAMPSHIRE PRACTICE: CIVIL PRACTICE AND
PROCEDURE, Ch. 39 (Equity, 1984). See

especially, id., Wiebusch, § 1380, n. 85

(Supp. 1989) ("The [N.H.] Supreme Court has
recently acknowledged that the Superior
Court judge usually gives a Master's Report
only cursory review before approving and

Signing it. State ex rel. Casinelli v.

Bourgeois, 127 N.H. 754, 506 A.2d 351 (1986)").

The “cursory review" in Your Petitioner's

case included denying Petitioner's requests
for de novo rehearing of disputed issues

by a duly-commissioned Superior Court

Justice, and denial of Petitioner's motion
for production of the transcript of pro-
ceedings before the Master, for review

by a Justice at a minimum. Thus, there

was no review whatever by any judicial

officer of any issue raised in this divorce
case.

The lack of hearing by any judicial
officer, and the consequent sole determination
of all issues by a non-judicial master—
lacking jurisdiction to decide cases—
worked a total deprivation of Fourteenth
Amendment due process of law to Petitioner's
disadvantage in this case.

The United States Court of Appeals
for the First Circuit reviewed a similar
challenge arising in a New Hampshire

divorce case, see, Witte v. Justices of the

New Hampshire Superior Court, 831 F.2d

362 (lst Cir. 1987), and concluded that
where the State litigant had the oppor-
tunity for de novo rehearing or some other
review of the proceedings before the Master,
the State system was constitutional as a
matter of due process of law, as was the

Federal Magistrate Act upheld in United

States v. Raddatz, 447 U.S. 667, 677-681

(1980), for the same reasons. Witte v.

Justices, supra, 831 F.2d, at 364.

However, this Court pointed out in

Raddatz, ibid, by its citation to Morgan

v. United States, 298 U.S. 468, 481 (1936)

("the one who decides must hear" the case
or address himself to the evidence in some
form) that a master or magistrate system
can survive constitutional challenge only
if a litigant is heard in some form by

a judicial officer on "those portions of
the magistrate's report to which objection

is made," as stated in Witte v. Justices,

supra, 831 F.2d, at 364, citing Raddatz.
Here there was no meaningful hearing
or even"appellate" review of the trans-
criptural record of proceedings before the
master by any Justice of the New Hampshire
Superior Court, on points contested by

Petitioner. Cf., Witte v. Justices, supra,

at 363 n.2; Bundy v. Wilson, 815 F.2d 125,

129 & n.3, 133 (lst Cir. 1987) (meaningful
appellate review of trial proceedings
impossible without review of transcript
or other adequate record as a matter of
due process of law).

Since it is undisputed that no judicial
officer heard or even reviewed evidence or
proceedings in this case, and the master
who heard and decided the case had no
authority or jusidiction to do so as a
clear matter of State law, a palpable
violation of the jurisdiction and hearing
requirement of the Due Process Clause of
the Fourteenth Amendment to the United
States Constitution appears in this case.

This fundamental constitutional
defect is a special and important reason
for this Court to grant this Petition.
This practice is routine in New Hampshire
and should be stopped by this Court, before

it spreads elsewhere.

III. PETITIONER WAS DENIED DUE PROCESS
OF LAW IN THE STATE DIVORCE CASE
BY BEING DENIED THE OPPORTUNITY
TO REVIEW THE FILE OF THE COURT-
APPOINTED GUARDIAN AD LITEM, THUS
OBSTRUCTING HIS RIGHT TO FULLY AND
EFFECTIVELY PREPARE FOR TRIAL ON
DISPUTED ISSUES OF CHILD CUSTODY
AND VISITATION, UPON WHICH THE
GUARDIAN MADE CONTESTED RECOMMEN-
DATIONS BASED ON INFORMATION IN
HIS FILE.

"[S]ince due process requires that either
parent have the opportunity to challenge any
evidence presented for consideration by the
trier of fact" in a divorce case, including

a report from a court-appointed guardian

ad litem, Ross v. Gadwah, 131 N.H. 391,

394, 554 A.2d 1284 (1988), even otherwise
privileged communications contained in
the GAL's file must be made available to
litigants, id., at 395.,

"Because ‘an essential requisite of
due process' is the right to be heard,
parents must be accorded that right in

custody proceedings...[which] must provide

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for ‘confrontation when adjudicativerights [or
facts] are in dispute....The right to be
heard includes the right to cross-examine
adverse witnesses....Parents rights of

due process therefore mandate that they
have an opportunity to counter evidence
that a fact-finder will rely on in reaching
a judgment determining their child's fate.
Therefore, none of the information the
guardian gathers can be shielded from
discovery" by the parties to the State

litigation. Ross v. Gadwah, supra, 131

N.H., at 395, 554 A.2d 1284.

Here it is not disputed that Your
Petitioner's request for access to the
guardian's file was denied by the GAL and
the trial master, and Petitioner was
accordingly denied effective confrontation
and contest of the facts relied on by

the Guardian in reaching his recommendation

against Petitioner having custody of his

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minor children in this divorce case.
This Court has also held in two
celebrated criminal cases that "[t]he
need to develop all relevant facts in
the adversary system is both fundamental
and comprehensive" as a matter of due

process of law, United States v. Nobles,

422 U.S. 225, 230-231 (1975), quoting

United States v. Nixon, 418 U.S. 683, 709

(1974), even as against a claim of
privilege from disclosure, id. "Pre-
viously recorded statements of witnesses
[are necessary] so that the [party] may
get the full benefit of cross-examination
and the truth-finding process may be

enhanced." United States v. Nobles, supra,

422 U.S., at 231.

It is an “ancient proposition of law”
...-that ‘the public...has a right to every
man's evidence.’ except for those persons

protected by a constitutional, common-law

or statutory privilege." Branzenburg v.

Hayes, 408 U.S. 665, 668 (1972), quoted

in United States v. Nixon, supra, 418 U.S.,

at 709.

The Guardian had no "privilege" pro-
tecting disclosure of the information
sought by Your Petitioner in this case.

Ross v. Gadwah, supra, 131 N.H., at 395,

554 A.2d 1284.

This Court has not clearly held that
these fundamental due process rights of
confrontation and trial preparation are
guaranteed by the Fourteenth Amendment in
State divorce cases where liberty interests
in child custody and visitation are at
stake.

These special and important fundamental
rights should be clarified by this Court
for the better administration of justice
in the several States, and this is a
substantial reason for the Court to allow

the writ herein.

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IV. PETITIONER WAS DENIED FOURTEENTH
AMENDMENT DUE PROCESS OF LAW AND/
OR THE EQUAL PROTECTION OF THE
LAWS WHERE RESPONDENT WAS ALLOWED
TO REMOVE THE CHILDREN FROM THE
STATE OF NEW HAMPSHIRE TO THE STATE
OF COLORADO, IN WHICH CASE THE
DIVORCE DECREE MANDATED A 73%
REDUCTION IN PETITIONER'S CUSTODY/
VISITATION WITH THE CHILDREN (FROM
169 DAYS PER YEAR TO A MERE 46),
CONTRARY TO PETITIONER'S FUNDAMENTAL
LIBERTY INTERESTS IN THIS CASE.

There is no doubt that "the role of

parents in the life of a family has attained
the status of a fundamental human right

and liberty. State v. Robert H. , 118

N.H. 713, 715, 393 A.2d 1387, 1388 (1978)."

Ross v. Gadwah, 131 N.H. 391, 395, 554 A.

2d 1284 (1988).
This Court has held the same as a matter

of Federal due process of law. Quilloin v.

Walcott, 434 U.S. 246, 255 (1978) ("one of
liberties protected by the Due Process
Clause of the Fourteenth Amendment"),

quoted in State v. Robert H. , ibid.

Moreover, this Court has implied that
the Equal Protection Clause may protect
liberty interests in child custody and
visitation matters and other aspects of

family life. Griswold v. Connecticut,

381 U.S. 479, 501 (1965) (Harlan, J.,
concurring), cited for the rule of

decision in State v. Robert H. , supra,

118 N.H., at 715, 393 A.2d 1387, 1388
("Appropriate limits [on family rights]
come not from drawing arbitrary lines but
rather from careful ‘respect for the teach-
ings of history [and] solid recognition
of the basic values that underlie our
society'").

Here, Your Petitioner's divorce

decree mandated that Respondent could

remove the children from the jurisdiction
of New Hampshire at her whim, in which
event Petitioner's rights of custody and

visitation would be massively curtailed

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automatically, without further judicial
review.

No rational basis or reasonable ground
of distinction was ever advanced as to
why Petitioner should be capriciously
deprived of so much of his relationship
with his children merely because Respondent
might unilaterally exercise her right to
move out of state. A much less restrictive
limitation might have addressed how trans-
portation expenses would be shared in the
event Respondent moved out of state, so
that Petitioner might be afforded nearly
all of his ordered access to the children
when they resided within New Hampshire.
Instead, the divorce decree merely reduced
the days of access to Petitioner's children
by 73 $.

It is plain that this reduction was
arbitrary and capricious, and unfair, and

accordingly offensive to both the Equal

Et i) ' eae o @ raf on se.

Protection and Due Process Clauses of
the Fourteenth Amendment, and this con-
stitutes a special and important reason
for this Court to allow the writ in this

matter.

CONCLUSION

For all of the foregoing reasons,
the petition for writ of certiorari to
the Supreme Court of New Hampshire should

be granted.

Respectfully submitted,

May 25, 1990

' obert sy ent Hg
20 Ledgewood Hills DriWe
Apartment No. 207
Nashua, N.H. 03062

(603) 881-9617

AFFIDAVIT OF FILING AND SERVICE

I hereby declare under penalty of
perjury that I have filed the requisite
number of copies of this Petition with
the Court by mailing the same, first class,
postage prepaid, certified mail, return
receipt requested, from New Hampshire
on May J6, 1990.

At the same time, I mailed the
requisite number of copies hereof to
opposing counsel, Luci S. Pilsbury, Esq.,
60 Main Street, Nashua, N.H. 03060 and
Robert G. Daniels, Esq., 19 Derry Road,

Hudson, N.H. 03051, by the same nT |

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STATE OF NEW HAMPSHIRE
Hillsborough , §S.

Then came the above-named J. Robert
Burk, Jr., personally known or satis-
factorily identified to me to be the
above-signed, and upon his oath declared
that the foregoing affidavit of filing
and service signed by him was true and
correct, and his voluntary act and deed,

under penalty of perjury.

May 45_, 1990

JUSTICE OF THE
PEACE

My commission expires:

Eleanor Benson

Notary Publie
My Commission Expires Aug. 14, 1994

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ADDENDUM
Appendix I
THE STATE OF NEW HAMPSHIRE
SUPREME COURT

In Case No. 89-482 J. Robert Burk, Jr. v.
Patricia A. Burk the court upon January 9,

1990 made the following order:

Plaintiff's motion for leave to file late
notice of appeal is granted. Decision below
is summarily affirmed in accordance with

Rule 25(1) (a).

Distribution:

Hillsborough County Superior Court
Mr. J. Robert Burk, Jr.

Luci Pillsbury, Esquire

Robert G. Daniels, Esquire

Donna R. Craig, Supreme Court

File

shin peace

«= 28 «

SUPREME COURT

In Case No. 89-482 J. Robert Burk, Jr. v.
Patricia A. Burk the court upon February 27,

1990 made the following order:

Plaintiff's motion for reconsideration is
denied. Defendant's motion for expedited

reconsideration is, therefore, moot.

Distribution:

Hillsborough County Superior Court
Mr. J. Robert Burk, Jr.

Luci Pillsbury, Esquire

Robert G. Daniels, Esquire

Donna R. Craig, Supreme Court

File

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