Bjerke v. Bjerke

6 Pa. D. & C.5th 381
CourtPennsylvania Court of Common Pleas, Alleghany County
DecidedOctober 14, 2008
Docketno. FD 04-8125-003
StatusPublished

This text of 6 Pa. D. & C.5th 381 (Bjerke v. Bjerke) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Alleghany County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bjerke v. Bjerke, 6 Pa. D. & C.5th 381 (Pa. Super. Ct. 2008).

Opinion

WECHT, J.,

This opinion addresses the issues of whether defendant Laura Rouseau (Wife) may testify at a hearing to re-open equitable distribution and whether this court may re-open equitable distribution after Richard J. Bjerke (Flusband)’s death.

BACKGROUND

Elusband and Wife married on October 11,1997. One child was bom during the marriage. Husband and Wife separated on September 23,2004, and divorced on June 5,2007. Husband married Elizabeth Ferrell (Ms. Bjerke) on July 13, 2007.

On May 7,2007, Husband and Wife executed a consent order for equitable distribution. Husband agreed to pay Wife $119,276 in cash and $100,000 in a transfer from [383]*383his retirement accounts. Wife agreed to a termination of the alimony/alimony pendente lite payments that she was receiving. Husband made the $119,276 cash payment. Husband was to inform Wife’s counsel which retirement account was to be used for the $100,000 transfer. Husband complied with this requirement as well. However, no QDRO was executed, and the transfer did not occur.

On April 12,2008, Husband took his own life. On May 23,2008, Wife presented a motion for entry of qualified domestic relations order. A hearing was scheduled on the matter. On June 25,2008, this court denied Wife’s request for a nunc pro tunc QDRO, but scheduled a hearing on Wife’s request to re-open equitable distribution. That hearing occurred on September 29, 2008.

DISCUSSION

The first issue to address is whether this court may consider testimony Wife gave at the September 29 hearing. Ms. Bjerke objected to Wife’s testimony as being precluded by the Dead Man’s Act. 42 Pa.C.S. §5930. This court denied Ms. Bjerke’s objection without prejudice, allowed Wife to testify, and preserved Ms. Bj erke’s objection so that her cross-examination did not constitute a waiver of the objection, and so that this court could strike the testimony (in whole or in part) if appropriate after taking the matter under advisement.

Under the Dead Man’s Act, a witness is disqualified from testifying in circumstances where: the deceased had an interest in the matter at issue; and the interest of the witness is adverse to the decedent’s estate; and the right of the deceased has passed to a party of record represent[384]*384ing the estate. In re Estate of Rider, 487 Pa. 373, 377, 409 A.2d 397, 399 (1979). The test for interest is whether a witness will gain or lose as a direct legal effect of the judgment. In re Groome's Estate, 337 Pa. 250, 252, 11 A.2d 271, 273 (1940). An interest is adverse when the immediate result of the particular suit would cause a loss or gain to the witness, not when the effect of the particular suit would arise in other possible actions. Billow v. Billow, 360 Pa. 343, 347, 61 A.2d 817, 819 (1948).

Generally, in cases where one spouse has died, testimony about a postnuptial agreement is precluded. In re Estate of Hartman, 399 Pa. Super. 386, 394, 582 A.2d 648, 652 (1990). Where the parties had an agreement to disclaim their elective shares, the husband could not testify about the validity of the agreement after the wife’s death. Id.1 In the Hartman case, the husband had the burden to show the agreement was invalid before he could attempt to elect against the estate of the wife. But the husband was precluded from testifying about the validity of the agreement, particularly with respect to whether there was full and fair disclosure.

The instant case is similar. Before she can re-open equitable distribution, Wife first must show that the agreement was not fulfilled. The Dead Man’s Act applies to “matters occurring before the death.” 42 Pa.C.S. §5930. Wife’s testimony regarding the attempt to obtain the QDRO, and about anything else that occurred after Husband died, is admissible. The other testimony by [385]*385Wife is excluded, and accordingly stricken from the record.

The second issue is whether equitable distribution should be re-opened. In the Reese case, there was an equitable distribution order upon which both parties relied and acted prior to the death of the wife. Reese v. Reese, 351 Pa. Super. 521, 522, 506 A.2d 471, 472-73 (1986). Because the parties willingly agreed to the order and had acted upon it, the wife’s death, prior to entry of a divorce decree, did not affect the agreement. Id. at 529, 506 A.2d at 475. Similarly, where the husband died after a marital settlement agreement and consent order had been entered, but prior to the divorce decree, the contract was found to be enforceable. In re Estate of Bullotta, 575 Pa. 587, 592, 838 A.2d 594, 597 (2003). InBullotta, the Supreme Court determined that the action required under the contract was not unique to the individual, and that the estate could complete the contract such that the contract was not voided by the husband’s death. Id.

These cases are distinguishable from the case at bar. In this case, the divorce decree issued before Husband died. Husband’s estate cannot complete the agreement. The estate cannot enter a QDRO, because the asset already has passed to the beneficiaries.

The crux of the issue — vigorously disputed by Wife and Ms. Bjerke — is whether this court has the authority to re-open equitable distribution. Most cases indicate that equitable distribution cannot be re-opened beyond the 30-day limit allowed by the rules. See e.g., Ratarsky v. Ratarsky, 383 Pa. Super. 445, 557 A.2d 23 (1989). Other cases, involving assets that were not included in equitable distribution, also have concluded that equitable distribu[386]*386tion should not be re-opened. See e.g., Major v. Major, 359 Pa. Super. 344, 518 A.2d 1267 (1986); Beamer v. Beamer, 330 Pa. Super. 154, 479 A.2d 485 (1984).

Two other cases, however, suggest that a trial court has the power to re-open equitable distribution in appropriate circumstances. Relying on 23 Pa.C.S. §3104 (a)(1), which provides continuing jurisdiction over the determination and disposition of property rights between spouses, 23 Pa.C.S. §3502(e)(4), which allows for an order for transfer or sale of property when a party does not comply with equitable distribution, and Pa.R.C.P. 1920.43, which allows the trial court to use equity powers to grant petitions for special relief, appellate courts approved re-opening of equitable distribution in Wagoner v. Wagoner, 538 Pa. 265, 648 A.2d 299 (1994), and Romeo v. Romeo, 417 Pa. Super. 180, 611 A.2d 1325 (1992).

In view of these latter cases, it appears that this court’s equity powers properly may be invoked now to modify equitable distribution.

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Related

Wagoner v. Wagoner
648 A.2d 299 (Supreme Court of Pennsylvania, 1994)
Commonwealth Trust Co. v. Szabo
138 A.2d 85 (Supreme Court of Pennsylvania, 1957)
In Re Estate of Rider
409 A.2d 397 (Supreme Court of Pennsylvania, 1979)
Reese v. Reese
506 A.2d 471 (Supreme Court of Pennsylvania, 1986)
In Re Estate of Hartman
582 A.2d 648 (Supreme Court of Pennsylvania, 1990)
Romeo v. Romeo
611 A.2d 1325 (Superior Court of Pennsylvania, 1992)
Major v. Major
518 A.2d 1267 (Supreme Court of Pennsylvania, 1986)
Ratarsky v. Ratarsky
557 A.2d 23 (Supreme Court of Pennsylvania, 1989)
In Re Estate of Bullotta
838 A.2d 594 (Supreme Court of Pennsylvania, 2003)
Beamer v. Beamer
479 A.2d 485 (Supreme Court of Pennsylvania, 1984)
Billow v. Billow, Liquidator
61 A.2d 817 (Supreme Court of Pennsylvania, 1948)
Groome's Estate
11 A.2d 271 (Supreme Court of Pennsylvania, 1940)

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Bluebook (online)
6 Pa. D. & C.5th 381, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bjerke-v-bjerke-pactcomplallegh-2008.