Nolan v. Nolan

CourtCourt of Special Appeals of Maryland
DecidedNovember 29, 2023
Docket0695/22
StatusPublished

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

Bluebook
Nolan v. Nolan, (Md. Ct. App. 2023).

Opinion

Christine Marie Nolan v. Michael W. Nolan, Jr., No. 0695, Sept. Term 2022. Opinion by Zic, J.

DIVORCE – EQUITABLE DISTRIBUTION OF TRUSTEE’S FEES

When conducting divorce proceedings, a trial court sits in equity and is granted broad discretionary authority to balance the equities of the parties when distributing marital property. The trial court committed no error by finding that equity required one party to pay the entirety of the trustee’s fees incurred after ordering the sale of the marital home and dividing the net proceeds equally pursuant to Real Property § 14-107. Circuit Court for Montgomery County Case No. 112910FL

REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 0695

September Term, 2022

CHRISTINE MARIE NOLAN

v.

MICHAEL W. NOLAN, JR.

Kehoe, Leahy, Zic,

JJ.

Opinion by Zic, J.

Filed: November 29, 2023

* Kehoe, Christopher B., J., now retired, participated in the hearing of this case while an active member of this Court, and after being recalled pursuant to the Constitution, Article IV, Section 3A, he also participated in the decision Pursuant to the Maryland Uniform Electronic Legal Materials and the adoption of this opinion. Act (§§ 10-1601 et seq. of the State Government Article) this * Tang, Rosalyn, J. and Albright, Anne, J. did document is authentic. not participate in the Court’s decision to 2023-11-29 15:02-05:00 designate this opinion for publication pursuant to Md. Rule 8-605.1.

Gregory Hilton, Clerk This case arises from a 2015 marital settlement agreement between appellant

Christine Nolan and appellee Michael Nolan. In March 2020, pursuant to terms of the

settlement agreement, Mr. Nolan filed a motion for sale of the marital home in the Circuit

Court for Montgomery County. The circuit court granted Mr. Nolan’s motion, appointed

a trustee, and ordered Ms. Nolan to pay for the costs of the trustee. 1 Ms. Nolan now

appeals and challenges the circuit court’s authority to order her to pay the full amount of

the trustee’s costs.

QUESTION PRESENTED

Ms. Nolan presents one question for our review, which we have rephrased and

reframed as follows: 2

Whether the circuit court erred in ordering Ms. Nolan to pay the entirety of the trustee’s costs.

For the reasons that follow, we answer Ms. Nolan’s question in the negative and affirm

the judgment of the circuit court.

1 Throughout the procedural history of this case, the $22,875 that Ms. Nolan was ordered to pay has been referred to as both the trustee’s “commission” and the trustee’s “costs.” This sum includes both the four percent commission awarded to the trustee for the sale of the Nolans’ marital home, totaling $22,000, and $875 in appraisal and filing fees paid by the trustee that are subject to reimbursement. In this opinion, for clarity, we will refer to the $22,875 that Ms. Nolan was ordered to pay as the trustee’s costs. 2 Ms. Nolan phrased the issue as follows: 1. Does a circuit court have the authority to order one co- tenant of real property to pay the entire trustee[’]s commission in a judicial sale? BACKGROUND

In July 2013, Mr. Nolan filed a Complaint for Absolute Divorce in the circuit

court. The parties entered into a marital settlement agreement (“Agreement”) on January

21, 2015. The circuit court incorporated but did not merge the terms of the Agreement in

its March 13, 2015 Judgment of Absolute Divorce. In relevant part, the settlement

granted Ms. Nolan exclusive use and possession of the marital home for a period of three

years following the formation of the Agreement. The Agreement also required Ms.

Nolan to pay all mortgage and maintenance expenses. 3 After either the expiration of the

exclusive use and possession period or Ms. Nolan’s remarriage, the marital home was to

be listed for sale. Any proceeds or deficiencies of the sale of the home were to be shared

equally between the parties.

Ms. Nolan remained in the home after the expiration of the three-year exclusive

use and possession period. 4 Ms. Nolan refused to sell following the expiration of the

period because she believed there was “not enough money to sell the property because of

the liens.” Mr. Nolan began paying half of the marital home’s mortgage in July 2019. 5

On March 13, 2020, Mr. Nolan filed a Motion for Sale of Former Marital Home, and on

3 For maintenance costs greater than $200, the parties were required to agree to the repair and share the cost equally. 4 There is some confusion regarding whether the three-year use and possession period expired in January 2018, three years after the Agreement was placed on the record, or in March 2018, three years after the divorce was finalized. In either event, the home was to be sold in early 2018. Throughout the exclusive use and possession period and until July 2019, Ms. 5

Nolan paid the mortgage of the marital home in full.

2 May 27, 2020, Ms. Nolan filed a timely Answer opposing the Motion for Sale.

Following a hearing on October 30, 2020, the circuit court granted the Motion for Sale on

November 6. The court appointed a trustee to conduct the sale, 6 and ordered Ms. Nolan

to provide a key and any relevant documents to the trustee to facilitate the sale of the

home. Finally, the court ordered Ms. Nolan to pay the trustee’s costs “unless [the court

determined] at a later hearing that those costs should be allocated in a different manner.”

During the October 30, 2020 hearing, the circuit court explained that Ms. Nolan’s

continued residence in the marital home nearly three years after the exclusive use and

possession period ended, along with Ms. Nolan’s continued refusal to list the property for

sale, was not what the parties agreed to in 2015. In short, “[t]he parties reached an

agreement; everyone understood what the agreement was; and that agreement was that

the [marital home] would be sold at the termination of the three years.” The court

explained that § 8-202(b)(2) of the Family Law Article grants the court the authority to

order the partition or sale of property. 7 Section 14-107 of the Real Property Article

6 Ms. Nolan did not protest the appointment of the trustee. 7 The transcript refers to “8-203(b)(2) of the Family Law Article” instead of § 8-202(b)(2). We assume that this is a transcription error. Section 8-202(b)(2) provides: (b) When the court determines the ownership of personal or real property, the court may: ... (2) as to any property owned by both of the parties, order a partition or a sale instead of partition and a division of the proceeds.

3 further allowed the circuit court to decree a partition or sale of real property. 8 Noting that

the circuit court “is a court of equity,” the court found that it would be inequitable for Ms.

Nolan to remain in the home any longer and granted Mr. Nolan’s motion for sale in lieu

of partition. Finding that Ms. Nolan benefited by remaining in the marital home for an

additional three years, with Mr. Nolan paying one-half of the mortgage for over a year,

the court ordered Ms. Nolan to pay the costs of the trustee appointed to sell the home.

The court also denied Mr. Nolan’s request to order Ms. Nolan to pay attorneys’ fees

because the court had already “order[ed] [Ms. Nolan] to pay for the trustee.”

On January 27, 2021, the trustee filed a Motion for Appropriate Relief after Ms.

Nolan failed to provide a key to the home as ordered in the November 6, 2020 order. The

motion was granted, and the trustee moved forward with listing and selling the home.

Ms.

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Bluebook (online)
Nolan v. Nolan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nolan-v-nolan-mdctspecapp-2023.