Rawlings v. Rawlings - Divorce Judgment Affirmation

Kansas Court of Appeals

Filed March 27th, 2026

Detected March 28th, 2026

Summary

The Kansas Court of Appeals affirmed a district court's decision to deny a motion to reconsider a divorce judgment. The court found the appellant failed to provide sufficient grounds for relief under K.S.A. 60-260(b) and did not meet the requirements for altering or amending the judgment.

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What changed

The Kansas Court of Appeals has affirmed a district court's denial of Jennifer Rawlings' motion to reconsider a divorce judgment. The appellate court found that Rawlings' motion, filed pro se, did not meet the criteria for relief from judgment under K.S.A. 60-260(b) as it lacked new evidence and failed to demonstrate diligence. Furthermore, her appellate brief was deficient in factual background, authority, and analysis, violating Supreme Court Rule 6.02(a)(4)-(5).

This ruling means the original divorce judgment and modification of maintenance stand. For legal professionals and parties involved in similar appeals, this case underscores the critical importance of adhering to procedural rules for appellate briefs, including providing adequate factual summaries and legal analysis. Failure to do so can result in the dismissal or affirmation of the lower court's decision, as demonstrated by the appellant's unsuccessful appeal.

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March 27, 2026 Get Citation Alerts Download PDF Add Note

In re Marriage of Rawlings

Court of Appeals of Kansas

Citations: None known
Docket Number: 128970
Precedential Status: Non-Precedential
Opinion
Authorities (1)
Cited By (0)
Summaries (0)
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Combined Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,970

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

In the Matter of the Marriage of

JENNIFER RAWLINGS,
Appellant,

and

CORY RAWLINGS,
Appellee.

MEMORANDUM OPINION

Appeal from Johnson District Court; DAVID W. HAUBER, judge. Submitted without oral
argument. Opinion filed March 27, 2026. Affirmed.

Jennifer Rawlings, appellant pro se.

Cory Rawlings, appellee pro se.

Before WARNER, C.J., ATCHESON and CLINE, JJ.

PER CURIAM: Jennifer Rawlings and Cory Rawlings were married in 2010, and
Jennifer filed for divorce in 2022. The parties entered a stipulation and property
settlement agreement reached through mediation, and the district court granted their
divorce soon after. The following year, Cory filed a motion to modify maintenance,
which the court granted after multiple hearings and after considering evidence presented
by both parties.

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Jennifer filed a pro se motion to reconsider, but this filing is not included in the
record on appeal. The record reflects that the district court denied the motion, finding
Jennifer was essentially trying to relitigate the same issues and arguments her attorney
had raised during the previous hearings. The court noted that because Jennifer did not file
the motion within 28 days as required for a motion to alter or amend under K.S.A. 60-
259(f), the court would only consider the pro se motion as one for relief from judgment
under K.S.A. 60-260(b). And the court held that Jennifer failed to make any showing
under K.S.A. 60-260(b) because she did not provide any new evidence or "even evidence
that could have been provided with reasonable diligence in the original proceedings."

Jennifer appealed the district court's decision to this court, titling her brief
"Emergency Motion to Strike Judgment and for Immediate Relief." This brief contains
almost no factual background, scant authority, and no analysis explaining or supporting
her requested relief—information our Supreme Court rules require a brief to contain and
that is essential to our review. See Supreme Court Rule 6.02(a)(4)-(5) (2026 Kan. S. Ct.
R. at 36). Without a factual summary, an appellate court cannot know what occurred that
gives rise to the appellant's claim of error. When an appellant does not provide a
comprehensible explanation of the issues raised or provide legal or logical support for
those issues, an appellate court cannot assess what relief may be appropriate or why.

We review the denial of a motion for relief from judgment filed under K.S.A. 60-
260(b) for an abuse of discretion. In re Marriage of Johnston, 54 Kan. App. 2d 516, 521,
402 P.3d 570 (2017). Jennifer, as the party claiming an error occurred, bears the burden
of showing the district court's ruling was based on an abuse of discretion. State v. Peters,
319 Kan. 492, 497-98, 555 P.3d 1134 (2024).

Self-represented litigants like Jennifer are still required to meet their burden within
the parameters required by our court rules—such as including a sufficient statement of
facts and pointing to legal authority to support the argument that an error occurred. Joritz

2
v. University of Kansas, 61 Kan. App. 2d 482, 511, 505 P.3d 775 (2022). Jennifer has not
provided enough information or authority to allow us to conclude that any error occurred
before the district court. We thus affirm the district court's judgment.

Affirmed.