Christine Rose Stonisch v. Rudolph Theodore Stonisch

CourtMichigan Court of Appeals
DecidedSeptember 28, 2023
Docket362982
StatusUnpublished

This text of Christine Rose Stonisch v. Rudolph Theodore Stonisch (Christine Rose Stonisch v. Rudolph Theodore Stonisch) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christine Rose Stonisch v. Rudolph Theodore Stonisch, (Mich. Ct. App. 2023).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

CHRISTINE ROSE STONISCH, UNPUBLISHED September 28, 2023 Plaintiff-Appellant,

v No. 362982 Oakland Family Division RUDOLPH THEODORE STONISCH, LC No. 2018-864749-DM

Defendant-Appellee.

Before: SHAPIRO, P.J., and M. J. KELLY and CAMERON, JJ.

PER CURIAM.

Plaintiff, Christine Stonisch, appeals as of right the trial court order confirming an arbitration award in favor of defendant, Rudolph Stonisch. We affirm for the reasons stated in this opinion.

I. BASIC FACTS

The parties married in 2001, and have three children. In July 2018, Christine filed a complaint for divorce. The parties reached a confidential settlement agreement in June 2019. Thereafter, the terms of the confidential settlement agreement were merged and incorporated into the parties’ August 1, 2019 consent judgment of divorce. The parties agreed to joint legal and physical custody of their children. As it relates to child support, the parties agreed that “in lieu of paying child support, [Rudolph] will maintain the financial status quo as set forth” in the confidential settlement agreement until the “status quo period” ends. As it relates to spousal support, the judgment provided that for 6.5 years, Rudolph would pay $12,000 per month in spousal support to Christine. However, during the status quo period “the $12,000 per month payment will be satisfied by (1) paying directly to [Christine] $7,500 per month, and (2) paying the other Status Quo expenses set forth in the agreement.”

The parties further agreed that an arbitrator would arbitrate any disputes (other than custody and parenting time) arising from the confidential settlement agreement. Relevant to this appeal, on July 23, 2021, Christine requested arbitration, alleging that Rudolph had breached the confidential settlement agreement “multiple” times by failing to pay status quo mortgage

-1- payments, which resulted in foreclosure’s and a sheriff’s sale of the parties marital home and other real estate.

On June 2, 2022, the arbitrator issued a final opinion and award regarding post-judgment arbitration. The arbitrator determined that the amount of debt to deduct from the purchase price of the marital house was $3,398,584 for two mortgages held by Rudolph’s mother’s trust plus $576,345 for the “Gregory” mortgage.

Additionally, the arbitrator found that Rudolph had breached the confidential settlement agreement by failing to make the mortgage payments on the marital home and on another property. The arbitrator noted that the failure to pay the mortgages resulted in the properties being foreclosed upon; however, he rejected Christine’s argument that the breach (i.e., failing to pay the mortgages) resulted in the properties being sold for substantially less money. The arbitrator recognized that, under the confidential settlement agreement, Christine had agreed that Rudolph would pay a reduced sum of money in spousal support and child support for the duration of the status quo period. But he rejected Christine’s argument that, because of Rudolph’s breach of the settlement agreement, the status quo period should be deemed to have ended in April 2019 and she should receive the full payment of the child support and spousal support.

On June 23, 2022, Christine moved to partially vacate the arbitrator’s award. She contended that the arbitrator exceeded his powers by (1) acting beyond the material terms of the agreement and the judgment of divorce and (2) by violating controlling law. Following a hearing, the trial court denied the motion to vacate the arbitrator’s award and, subsequently, entered a final order affirming the arbitrator’s judgment.

II. MOTION TO VACATE ARBITRATION AWARD

A. STANDARD OF REVIEW

Christine argues that the trial court erred by not setting aside the arbitration award.1 We review de novo a trial court’s decision to deny a motion to vacate or modify an arbitration award. Washington v Washington, 283 Mich App 667, 671; 770 NW2d 908 (2009). Consequently, no deference is extended to the trial court’s decision. Id. Moreover, judicial review of domestic relations arbitration awards “is usually extremely limited.” Id. As it relates to a domestic relations arbitration award, our Legislature has provided four limited circumstances under which such an award may be vacated. See MCL 600.5081(2). As relevant to this case, under MCL 600.5081(2)(b), an award may be vacated if “[t]he arbitrator exceeded his or her powers.” This Court reviews de novo whether the arbitrator exceeded his or her powers. Washington, 283 Mich App at 672. “[A] party seeking to prove that a domestic relations arbitrator exceeded his or her

1 In his brief on appeal, Rudolph argues that this Court should dismiss Christine’s appeal for lack of jurisdiction because the court’s order confirming the arbitrator’s award was not a final order under MCR 7.202(6)(a). However, he raised the same argument in a motion to dismiss filed with this Court. We denied that motion. Stonisch v Stonisch, unpublished order of the Court of Appeals, entered February 2, 2023 (Docket No. 362982). We decline Rudolph’s invitation to reconsider our prior decision.

-2- authority must show that the arbitrator either (1) acted beyond the material terms of the arbitration agreement or (2) acted contrary to controlling law.” Id. No review of the arbitrator’s factual findings is permitted. Id. Further, “any error of law must be discernible on the fact of the award itself,” i.e., it must be a legal error “that is evident without scrutiny of intermediate mental indicia.” Id. (quotation marks and citation omitted). “Finally, in order to vacate an arbitration award, any error of law must be so substantial that, but for the error, the award would have been substantially different.” Id.

B. ANALYSIS

1. ACTIONS BEYOND THE MARITAL TERMS OF THE SETTLEMENT AGREEMENT

Christine first argues that the arbitrator exceeded his authority because he acted beyond the marital terms of the confidential settlement agreement. Specifically, she argues that the settlement agreement unambiguously provides that $3,398,584 will be deducted from the proceeds of the sale of the marital house, and that Rudolph will be 100% responsible for any additional indebtedness. The arbitrator, however, deducted the $3,398,584 plus $576,345 for what the parties refer to as the Gregory mortgage. In response, Rudolph argues that the arbitrator did not act beyond the scope of the agreement. Rather, the arbitrator found the agreement to be ambiguous and then relied upon parol evidence to interpret it.

A reviewing court must accept the arbitrator’s factual findings and decisions on the merits, and it cannot engage in contractual interpretation because that is an issue reserved for the arbitrator. Ann Arbor v AFSCME, 284 Mich App 126, 144; 771 NW2d 843 (2009). “Thus, as long as the arbitrator is even arguably construing or applying the contract and acting within the scope of his authority, a court may not overturn the decision even if convinced that the arbitrator committed a serious error.” Id. (quotation marks and citation omitted).

Here, the settlement agreement provided, in relevant part:

e) Calculation of [marital house] Net Sale Proceeds:

Contemporaneously with the closing of the sale of the [marital house], the following liabilities (which [Rudolph] represents encumbers [the marital house]) will be paid from the gross [marital house] sale proceeds:

i) Customary costs of sale, including realtor commissions and fees;

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Related

Washington v. Washington
770 N.W.2d 908 (Michigan Court of Appeals, 2009)
Miller-Davis Co. v. Ahrens Construction, Inc.
848 N.W.2d 95 (Michigan Supreme Court, 2014)
in Re Lett Estate
887 N.W.2d 807 (Michigan Court of Appeals, 2016)
City of Ann Arbor v. American Federation of State Employees Local 369
771 N.W.2d 843 (Michigan Court of Appeals, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Christine Rose Stonisch v. Rudolph Theodore Stonisch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christine-rose-stonisch-v-rudolph-theodore-stonisch-michctapp-2023.