Erica McNicol v. David Mcnicol

CourtCourt of Appeals of Washington
DecidedFebruary 4, 2025
Docket59212-6
StatusUnpublished

This text of Erica McNicol v. David Mcnicol (Erica McNicol v. David Mcnicol) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erica McNicol v. David Mcnicol, (Wash. Ct. App. 2025).

Opinion

Filed Washington State Court of Appeals Division Two

February 4, 2025

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

In re the Marriage of: No. 59212-6-II

ERICA LYN McNICOL,

Respondent,

and UNPUBLISHED OPINION

DAVID JOSEPH McNICOL,

Appellant.

VELJACIC, J. — David McNicol and Erica McNicol’s dissolution decree incorporated a CR

2A agreement that awarded the marital home to David1 and ordered him to be responsible for the

mortgage on the home. In a subsequent order, the trial court found that being responsible for the

mortgage meant removing Erica’s name from the mortgage and ordered David to remove her name

by December 5, 2024. The court also denied attorney fees. David appeals the trial court’s order,

arguing that the court erred in ordering him to remove Erica’s name from the mortgage and in

denying his request for attorney fees. We affirm.

FACTS

The trial court dissolved the parties’ 23 year marriage in June 2022. The court incorporated

into the dissolution decree the parties’ CR 2A agreement. The agreement provided that David

1 Because the parties share the same last name, we use their first names for clarity. No disrespect is intended. 59212-6-II

would receive the family home and that he “shall be responsible for the mortgage.” Clerk’s Papers

(CP) at 2. The agreement also provided that David “shall pay the sum of $250,000 to [Erica]

within 90 days of entry of the Degree of Dissolution, representing her share of equity in the family

home.” CP at 2. Regarding attorney fees, the agreement provided that in the event of a dispute,

“[t]he prevailing party shall be entitled to an award of his or her attorney’s fees.” CP at 3. The

agreement is drafted on David’s attorney’s pleading paper.

David timely paid the $250,000 equity payment to Erica. And Erica signed a quit claim

deed releasing her legal interest in the real property to David. Erica thought that when David paid

her the equity payment, he had refinanced the home and removed her name from the mortgage.

In May 2023, Erica learned her name was still on the mortgage. She claims she found this

out when applying for another loan and was denied due to her high debt ratio.

In October 2023, Erica moved for an order to enforce the dissolution degree and require

David to remove her name from the mortgage. She also requested attorney fees.

On December 5, 2023, the trial court found that the language in the CR 2A agreement

regarding the mortgage obligation was ambiguous. The court also found that the parties did not

act in bad faith, but keeping Erica’s name on the mortgage was likely to affect her credit score,

debt-to-income ratio, and ability to borrow money. The court concluded that it had the authority

to clarify the ambiguous term and ordered David to remove Erica’s name from the mortgage within

12 months. The court denied attorney fees.

David filed a motion for reconsideration, which the trial court denied. David appeals.

2 59212-6-II

ANALYSIS

I. ORDER TO REMOVE ERICA FROM MORTGAGE

David argues that the trial court erred in finding that a term in the parties’ CR 2A agreement

was ambiguous and in interpreting the agreement to include a requirement that David remove Erica

from the home’s mortgage. He further alleges the court erred by adding an obligation to the

contract that was not contemplated by the parties. We disagree.

We interpret CR 2A agreements by applying normal contract principles. In re Marriage

of Pascale, 173 Wn. App. 836, 841, 295 P.3d 805 (2013). Where parties dispute a contract’s

language, a court determines the parties’ intent by analyzing the agreement’s “‘objective

manifestations’” rather than the “‘unexpressed subjective intent’” of the parties. In re Matter of

Est. of Petelle, 195 Wn.2d 661, 665, 462 P.3d 848 (2020) (quoting Hearst Commc'ns, Inc. v. Seattle

Times Co., 154 Wn.2d 493, 503, 115 P.3d 262 (2005)). Generally, words in a contract are given

their “ordinary, usual, and popular meaning.” Condon v. Condon, 177 Wn.2d 150, 162-63, 298

P.3d 86 (2013). Contract language is ambiguous if it is susceptible to two different but reasonable

interpretations. Kut Suen Lui v. Essex Ins. Co., 185 Wn.2d 703, 712, 375 P.3d 596 (2016). If a

term is ambiguous, “‘we may rely on extrinsic evidence [to determine] the intent of the parties to

resolve the ambiguity.’” Id. (quoting Quadrant Corp. v. Am. States Ins. Co., 154 Wn.2d 165, 172,

110 P.3d 733 (2005)). An ambiguous term is construed against the drafter. Sprague v. Safeco Ins.

Co. of Am., 174 Wn.2d 524, 528, 276 P.3d 1270 (2012).

We review de novo a trial court’s interpretation of a CR 2A agreement. Pascale, 173 Wn.

App. at 841.

Here, the trial court incorporated into the parties’ dissolution decree their CR 2A

agreement. The agreement provided that David would receive the family home and “be

3 59212-6-II

responsible for the mortgage.” CP at 2. Because “responsible” could mean simply paying the

mortgage or being the sole person on the mortgage, we agree with the trial court that in this case

“responsible” is an ambiguous term. We, therefore, look to the contract as a whole and the parties’

subsequent actions to determine the parties’ intent.

David was awarded the house, Erica quit claimed her interest in the house to David, and

David paid Erica her share of the equity. Combining the contract language with the parties’

subsequent actions, the parties’ intent was that David would be “responsible” for the mortgage by

being the sole debtor on the mortgage. Leaving Erica’s name on the mortgage could entail her

being responsible for the mortgage if David defaults. Moreover, it would impact Erica’s credit

score and debt-to-income ratio.

Additionally, it appears from our record that David’s attorney drafted the CR 2A

agreement. As set forth above, we construe an ambiguous term against the drafter. Sprague, 174

Wn.2d at 528.

Lastly, based on our holding above, we are unpersuaded by David’s argument that the trial

court added an obligation to the contract that was not contemplated by the parties.

Accordingly, we hold that the trial court did not err in finding the term “responsible” to be

ambiguous. We further hold that based on the contract language and the parties’ subsequent

actions, the parties’ intent was that David would be responsible for the mortgage by being the sole

person listed on the mortgage. The court properly ordered David to remove Erica’s name from

the mortgage.

II. ATTORNEY FEES BELOW

David argues that he should have been awarded his attorney fees below based on the

attorney fees clause in the parties CR 2A agreement. We disagree.

4 59212-6-II

We review de novo whether there is a legal basis for awarding attorney fees, and we review

a trial court’s decision to award attorney fees, and the reasonableness of the award, for an abuse

of discretion. Gander v. Yeager, 167 Wn. App. 638, 647, 282 P.3d 1100 (2012).

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110 P.3d 733 (Washington Supreme Court, 2005)
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In re the Marriage of Pascale
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