Carmen Salgado v. James Meiers

CourtNew Jersey Superior Court Appellate Division
DecidedMay 15, 2024
DocketA-1040-22
StatusUnpublished

This text of Carmen Salgado v. James Meiers (Carmen Salgado v. James Meiers) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carmen Salgado v. James Meiers, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLAT E DIVISION DOCKET NO. A-1040-22

CARMEN SALGADO,

Plaintiff-Respondent,

v.

JAMES MEIERS,

Defendant-Appellant. ________________________

Submitted January 24, 2024 – Decided May 15, 2024

Before Judges Accurso and Walcott-Henderson.

On appeal from the Superior Court of New Jersey, Chancery Division, Family Part, Hudson County, Docket No. FM-09-2595-08.

Heymann & Fletcher, attorneys for appellant (Alix Claps, on the brief).

Respondent has not filed a brief.

PER CURIAM

Defendant-father appeals from a November 4, 2022 Family Part order

granting plaintiff-mother's motion in-part enforcing litigants rights and compelling defendant to contribute to their child's college tuition and expenses.

At issue is whether defendant violated the parties' Property Settlement

Agreement ("PSA") by failing to contribute to college tuition and expenses and

by claiming their child as a dependent in 2021. We affirm.

At the time of their divorce in 2009, the parties executed a PSA which

explicitly included support for their child, the sole child of the marriage. Under

the terms of their PSA, the parties recognized their responsibility to provide a

college education for their child "dependent upon their ability to pay[.]"

The PSA included a separate provision for "college education/college

accounts," which states in pertinent part:

Both parties recognize that, under current New Jersey law, as divorced parents they are both responsible for providing a college or other post-secondary education for their child dependent upon their ability to pay at that time and the child's aptitude, opportunities and inclinations. The contributions of the parties shall be calculated after all applicable and/or available student loans, grants and scholarships have been applied for and the child's accounts have been fully accessed to the extent allowable. The child shall have an obligation to contribute by working summers and during the school recesses, if possible. The parties anticipate sharing these expenses based on the guidelines percentages that are in effect at the time the child enters college. The child's loans shall be his responsibility unless the parties voluntarily decide to contribute. In other words, the parties shall have no obligation to pay for the child's loans.

A-1040-22 2 There is no dispute plaintiff and defendant participated in the child's

selection of a college and equally shared the cost of tuition for the first year and

that defendant failed to contribute to the costs of college tuition during their

child's sophomore year.

Additionally, per Article III paragraph 8 of their PSA, the parties had

agreed to alternately claim their child as a dependent every other year with

defendant claiming the tax credit in even years and plaintiff in odd years. There

is no dispute in the record that defendant claimed their child in 2021 when it

was plaintiff's designated year.

Plaintiff moved to enforce litigant's rights and for an order compelling

defendant to pay fifty percent of the child's sophomore college tuition and

expenses; for an order requiring defendant to amend his 2021 income tax return

to remove the child as a dependent—allowing plaintiff to claim the child on her

2021 income tax return and every odd year thereafter; counsel fees; and to

enforce the $98.00 a week child support obligation.

Defendant, then-self-represented, replied in an opposition styled as an

"answer to plaintiff's motion and request for relief." He maintained the PSA

"grants [him] the discretion to contribute to [their child's] college education as

[defendant] deem[s] [he is] able," and that for the first year he "took a loan for

A-1040-22 3 $15,000 and [he] still owe[d] $12,500 on this loan." Thus, he argued, "[his]

determination that [he] cannot contribute further to college costs at this time is

based on experience and is not capricious."

As to the head of household tax credit, defendant maintained that:

Article III, paragraph 8 of the PSA is no longer binding on the Parties. Further, paragraph 9 of the Certification Affidavit shows the years that each Party was permitted to claim [the child] as a dependent and ends at 2020. This paragraph thus demonstrates that the Parties had not yet come to an agreement over who would claim [their child] as a dependent in 2021.

[Id. at 84.]

At the hearing, defendant testified that at the time of the PSA "I was not making

a commitment to pay [] half of [their child's] tuition, 15 years in the

future. . . . And, freshman year, I gave it a shot and I just could not continue to

do it."

In an oral decision, the Family Part judge found defendant violated the

terms of the PSA by failing to contribute to their child's college tuition and

expenses. The court noted the parties jointly participated in their child's college

selection—having specifically considered Syracuse's accelerated engineering

program and work-study. Although it found, "no obligation in their agreement

or subsequent written document confirming . . . that they would each pay 50/50

A-1040-22 4 of the cost," the court concluded the parties "anticipated sharing these expenses

based on the guidelines percentages that are in effect at the time that the child

attends college," based on the explicit language of the PSA. The court granted

plaintiff's motion in-part—declining to equally divide college tuition—finding

that defendant violated litigant's rights by prematurely claiming their child on

his 2021 tax returns, clarified that plaintiff was entitled to claim the child in odd

years, and continued defendant's child support obligation, stating "there's no

motion before me to modify."

In its subsequent written decision on plaintiff's fee application, the court

noted that "[d]efendant did not file a cross-motion, and thus, [d]efendant does

not have any requests pending before the [c]ourt at this time." The court further

found that it was "unable to make findings on [d]efendant’s current financial

circumstances as the record properly before the [c]ourt today is silent regarding

same."

Defendant appeals and presents the following arguments:

I. THE TRIAL COURT ERRED BY MISSTATING THE PARTIES' PSA AND INACCURATELY LIMITING STUDENT LOANS TO "SUBSIDIZED" LOANS.

II. THE TRIAL COURT ERRED IN IGNORING THE SPECIFIC LANGUAGE OF THE PSA THAT MAKES

A-1040-22 5 THE STUDENT SOLELY RESPONSIBLE FOR REPAYMENT OF HIS STUDENT LOANS.

III. THE TRIAL COURT ERRED IN NOT ASSESSING THE PARTIES' CURRENT ABILITY TO PAY AND PROPORTIONAL INCOME, BUT RATHER RELYING ON A CALCULATION FROM 2012.

IV. (NOT RAISED BELOW) THE TRIAL COURT ERRED IN FAILING TO HOLD A PLENARY HEARING REGARDING COLLEGE CONTRIBUTION.

V. THE TRIAL COURT ERRED IN NOT MODIFYING DEFENDANT’S CHILD SUPPORT OBLIGATION BASED ON THE CHILD NO LONGER RESIDING WITH PLAINTIFF.

VI. THE TRIAL COURT ERRED BY NOT ADDRESSING THE AFFIRMATIVE RELIEF SOUGHT BY DEFENDANT AND IGNORING WHAT SHOULD HAVE BEEN CONSTRUED AS A CROSS-MOTION.

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Cite This Page — Counsel Stack

Bluebook (online)
Carmen Salgado v. James Meiers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carmen-salgado-v-james-meiers-njsuperctappdiv-2024.