Geoghegan — affirmed wife’s attorney-fee award because husband’s challenges were unpreserved

Case
In the Matter of the Marriage of Angela Ceris Geoghegan, nka Angela Ceris Hamilton, Petitioner-Respondent, and Patrick Justin Geoghegan, Respondent-Appellant
Court
Oregon Court of Appeals
Judge
Joyce, Presiding Judge; O’Connor, Judge; DeVore, Senior Judge
Date Decided
September 30, 2026
Docket No.
A189670
Topics
Attorney Fees; Preservation; Divorce; Civil Procedure
Source
Read the full opinion

Background

After the parties’ marriage was dissolved, wife petitioned for attorney fees in May 2025 and submitted a proposed supplemental judgment awarding those fees in December 2025. Husband filed an objection to the proposed judgment but did not request a hearing in the objection’s caption.

The trial court entered a supplemental judgment awarding wife attorney fees and stated that husband had not filed any response or objection. On appeal, husband argued that the court erred by overlooking his objection, awarding fees, and failing to make findings sufficient for appellate review.

The Court’s Holding

The Oregon Court of Appeals affirmed. Although the trial court incorrectly stated that husband had not filed an objection, husband filed his objection well beyond ORCP 68 C(4)(b)’s 14-day deadline and did not seek additional time under ORCP 68 C(4)(d)(ii).

Husband also failed to request a hearing in the caption, as ORCP 68 C(4)(e) requires for entitlement to a hearing. Because a hearing would have given the trial court an opportunity to make the findings husband claimed were missing, the appellate court concluded that his arguments were unpreserved.

Key Takeaways

  • An objection to an attorney-fee petition must be filed within ORCP 68 C(4)(b)’s 14-day period unless additional time is obtained.
  • A party seeking a hearing on attorney fees must include the hearing request in the objection’s caption.
  • The trial court’s mistaken statement that no objection had been filed did not warrant reversal because husband’s objection was untimely and his appellate arguments were unpreserved.

Why It Matters

The decision underscores that strict compliance with Oregon’s attorney-fee procedures is essential. Filing an objection alone may not preserve a challenge when it is late and does not properly request a hearing.

The opinion is a nonprecedential memorandum opinion under ORAP 10.30 and may be cited only as that rule permits.

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