Jenkins v. Jenkins

71 Pa. D. & C.4th 205, 2004 Pa. Dist. & Cnty. Dec. LEXIS 296
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedOctober 25, 2004
Docketno. 1204 D.R. 2001, no. 8089 CIVIL 2001
StatusPublished
Cited by1 cases

This text of 71 Pa. D. & C.4th 205 (Jenkins v. Jenkins) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jenkins v. Jenkins, 71 Pa. D. & C.4th 205, 2004 Pa. Dist. & Cnty. Dec. LEXIS 296 (Pa. Super. Ct. 2004).

Opinion

WORTHINGTON, J,

Plaintiff, Chong Suk Cha Jenkins (Wife) and defendant, Allan Paul Jenkins (Husband) were married on May 27, 1981. On November 28, 1994, the parties entered into a “post-nuptial agreement.” They did not physically separate until August of2000. OnNovember 9,2001, Wife filed a complaint requesting a divorce pursuant to section 3301(c) ofthe Pennsylvania Divorce Code. OnFebruary 13,2004, Wife filed a motion to convert the divorce action to a divorce pursuant to section 3301(d), a motion for entry of decree in divorce, a motion to enforce the postnuptial agreement, and a motion for award of counsel fees. On February 18, 2004, we issued a rule returnable on Husband and he filed an answer on March 9, 2004, alleging that the agreement should not be enforced because neither party had been abiding by its terms. Husband further maintained that Wife was precluded from seeking relief by the statute of limitations and the doctrine of laches. Arguments were held on August 10, 2004, and Wife’s motions are now before us for disposition.

Neither party objects to the entry of a decree in divorce pursuant to section 3301(d) of the divorce code. Husband and Wife have met all of the requirements of section 3301(d) and have been separated in excess ofthe requisite statutory period. We will therefore convert the instant divorce action from section 3301(c) to section 3301(d) and enter a decree in divorce.

A consideration of whether the agreement at issue is actually a postnuptial agreement, or more precisely a midnuptial agreement, is not necessary for the purposes of resolving this dispute, as such a distinction turns on little more than semantics. The relevant discussion in this [207]*207case is whether the agreement at issue is a postnuptial agreement or a separation agreement. The answer depends upon the intent of the parties as gathered from all of the relevant facts.

A postnuptial agreement is typically a contract entered into after marriage by a husband and wife, generally involving the property or property rights of the parties. Vaccarello v. Vaccarello, 563 Pa. 93, 97, 757 A.2d 909, 911 (2000). A postnuptial agreement differs from other types of marital agreements in that it generally resolves property rights definitively. Where spouses desire to “settle and determine their respective property rights finally and for all time, [their agreement] should be construed as a postnuptial agreement.” Id., citing Makowski v. Makowski, 163 Pa. Super. 441, 443, 62 A.2d 71, 72 (1948). Moreover, liability under a postnuptial agreement is not automatically terminated by reconciliation of the parties or subsequent divorce. Commonwealth ex rel. Egolf v. Egolf, 49 D.&C.2d 400, 401 (1970); Commonwealth ex rel. DiValerio v. DiValerio, 169 Pa. Super. 477, 479-80, 82 A.2d 687, 688 (1951).

This is in sharp contrast to separation agreements. A separation agreement does not constitute, nor is it intended to constitute, “a full and final determination of the separate property rights of the parties.” Wareham by Trout v. Wareham, 716 A.2d 674, 677 (Pa. Super. 1998). Rather, separation agreements “customarily [represent] a surrender of the wife’s right to support in consideration of some property settlement.” Id. Furthermore, a subsequent reconciliation of the parties will terminate the separation agreement. Vaccarello at 97, 757 A.2d at [208]*208911, citing In re Ray’s Estate, 304 Pa. 421, 426, 156 A. 64, 65 (1931).

Here, it is our determination that Husband and Wife, in creating and signing the agreement, specifically intended for it to survive any potential subsequent reconciliation. The agreement provides:

“[N] either party presently contemplates any action to dissolve the marriage and each expresses the wish that the marriage continue until the death of one of them; but, each party recognizes the fragility of the situation and the economic and emotional realities of life . . . .” Postnuptial agreement at 1, 2.

Not only did the agreement specifically contemplate the potential for a subsequent reconciliation, it also contained a specific provision granting each party the right to pursue a divorce. Said provision imparts:

“This agreement shall not prevent or be construed to prevent either party from instituting proceedings or continuing proceedings already instituted to secure a divorce on just and proper grounds, nor shall it prevent the other party from making any defense thereto.” Postnuptial agreement at 18, paragraph 17.

It is clear that the agreement, as written, contemplated a possible reunion of the parties. Additionally, the potential for a subsequent divorce was also expressly contemplated by both parties at the time they entered into the agreement. The Superior Court has held that when a postnuptial agreement is a complete property settlement agreement and maintains its independent contractual status, any subsequent reconciliation or remarriage of the parties does not abrogate the agreement. Wareham by [209]*209Trout v. Wareham, 716 A.2d 674, 677 (Pa. Super. 1998), citing Commonwealth ex rel. DiValerio v. DiValerio, 169 Pa. Super. 477, 479-80, 82 A.2d 687, 688 (1951). Because the agreement at issue anticipated divorce and was intended to survive a decree in divorce, the agreement maintains its independent contractual status despite the subsequent reconciliation of the parties. We therefore will not terminate the agreement on the ground that the parties resumed and maintained a relationship for approximately six years following the execution of the agreement.

Furthermore, we find that both Husband and Wife, via the terms of the agreement, expressed an unequivocal desire to settle and determine their respective property rights finally and for all time. The language of the agreement states, in pertinent part:

“[T]he parties intend by this agreement to fix and determine the equitable distribution rights of each of them in any and all property of every nature and description and wheresoever situated which the other presently owns or may hereafter acquire during his or her lifetime, and to mutually restrict the rights that each might otherwise have or hereafter acquire in the property, income or estate of the other by virtue of the marriage in order to preserve his or her own rights to freely dispose of his or her property or income during his or her lifetime, and the parties also desire by this agreement to fix and determine their rights and obligations with respect to alimony, alimony pendente lite, support and other economic issues in the event either party wishes at any time to bring an action to dissolve the marriage; and ...

[210]*210“[B]oth parties have discussed the terms and conditions, the implications and monetary considerations involved between themselves, and they desire to set forth their agreement in writing, without any force, coercion, intimidation or promise other than those convenants [sic] expressed herein, and they do fully and voluntarily enter into this agreement; and...

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Bluebook (online)
71 Pa. D. & C.4th 205, 2004 Pa. Dist. & Cnty. Dec. LEXIS 296, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jenkins-v-jenkins-pactcomplmonroe-2004.