Dulaney v. Dulaney is an unpublished May 2011 decision from the South Carolina Court of Appeals.  The primary issue on appeal was whether the mother waived the requirement that father pay the minor child’s private school tuition.  The family court refused to hold father in contempt but required him to reimburse mother for two years of back tuition.  While the family court refused to make any credibility determination to resolve the factual dispute, despite father’s motion for reconsideration asking it to do so, the Court of Appeals affirmed the family court finding that “the court’s order implicitly reflects a determination Mother was credible on the issue of the parties’ agreement concerning the tuition.”  For further information see:  Beaten by implicit credibility determinations.

Put Mr. Forman’s experience, knowledge, and dedication to your service for any of your South Carolina family law needs.

Recent Blog Posts

It’s not easy to repudiate an executed South Carolina domestic relations agreement

Multiple times every year—three times in the past week—I hear from a South Carolina family court litigant who wishes to repudiate an agreement

[ + ] Read More

How South Carolina’s new family court temporary hearing rule changes my temporary hearing preparation

On October 1, 2025, South Carolina began implementing a new version of Rule 21, SCRFC, addressing the procedures for family court temporary hearings. 

[ + ] Read More

What can be addressed in a reconciliation agreement?

I have long thought that reconciliation agreements (also called postnuptial agreements) were of questionable validity. In prenuptial agreements, unmarried parties intend to enter

[ + ] Read More