Peter Chatel v. Leslie P. Carroll

CourtCourt of Appeals of Georgia
DecidedFebruary 6, 2023
DocketA22A1336
StatusPublished

This text of Peter Chatel v. Leslie P. Carroll (Peter Chatel v. Leslie P. Carroll) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peter Chatel v. Leslie P. Carroll, (Ga. Ct. App. 2023).

Opinion

FOURTH DIVISION DILLARD, P. J., MERCIER and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

February 6, 2023

In the Court of Appeals of Georgia A22A1336. CHATEL v. CARROLL.

MARKLE, Judge.

In this discretionary appeal, Peter Chatel challenges the trial court’s order

finding him in willful contempt of a divorce settlement agreement after he

(1) withheld proceeds from his ex-wife’s, Leslie P. Carroll, exercise of certain stock

options awarded in the divorce; and (2) failed to timely provide documents his ex-

wife requested. On appeal, Chatel contends the trial court (1) impermissibly modified

the terms of the settlement agreement and erred by holding him in contempt; (2)

improperly awarded damages for breach of contract in a contempt action; (3)

miscalculated the amount of statutory interest under the applicable statute; and (4)

erred by awarding attorney fees and expenses without sufficient evidence. For the

reasons that follow, we conclude that the trial court erred by finding Chatel in contempt with regard to the stock options, and therefore we reverse that contempt

finding and the resulting damages and interest. We affirm the attorney fees award and

finding of contempt regarding the documents.

[T]he trial court in a contempt case has wide discretion to determine whether its orders have been violated. The court is not authorized to modify a previous decree in a contempt order, but it is always empowered to interpret and clarify its own orders. If there is any evidence to support a trial court’s determination that its order has been willfully violated, this Court must affirm that determination on appeal. However, where a contempt action turns on the meaning of terms in an incorporated settlement agreement, construction of those terms is a question of law that is subject to de novo review on appeal.

(Citations and punctuation omitted.) Vaughn v. Vaughn, 365 Ga. App. 195, 198 (1)

(877 SE2d 860) (2022); see also Sutherlin v. Sutherlin, 301 Ga. 581, 582 (802 SE2d

204) (2017).

So viewed, the record shows that Chatel and Carroll divorced in 2005 after 20

years of marriage. The parties entered into a settlement agreement, which was

incorporated into the final divorce decree. As part of the division of property, the

settlement agreement1 provided that Carroll would receive 50 percent of Chatel’s

1 Section 5.01 of the settlement agreement provided: “Wife shall own, have, and enjoy as her separate property . . . One half of the vested and unvested stock

2 stock options from his then-employer.2 Per the agreement, Carroll was “responsible

for the taxes and any cost necessary to effectuate her exercise of said stock options.”

Otherwise, the settlement agreement did not specify how Carroll would exercise the

stock options, nor how the taxes would be calculated if she did so. The parties

developed their own ad hoc method of effectuating the transfers. When she wished

to exercise an option, Carroll would e-mail Chatel, who would exercise the stock

options in his name, and then liquidate them before giving the proceeds to Carroll.

The employer would withhold from the proceeds 25 percent of the stock value in

taxes. Because Chatel believed that the stock proceeds placed him in a higher tax

bracket and increased his income tax liability beyond the amount withheld, he

unilaterally kept an additional 14.6 percent of Carroll’s proceeds from each sale of

stock. The agreement further specified that each party must deliver to the other any

documents necessary to effectuate the provisions of the settlement agreement, and

options related to stock in the [employer] as of December 31, 2004[.]” Section 5.02 provided the same for Chatel. 2 Because the stock options are non-transferrable, they remained in Chatel’s name and control.

3 must pay to the other any attorney fees and expenses incurred as a result of the failure

to do so.3

Between 2010 and 2017, Carroll exercised the stock options eight times. In

2018, Carroll obtained Chatel’s tax returns.4 Based on those tax returns, Carroll

moved for contempt, alleging that Chatel violated the settlement agreement by

improperly withholding additional taxes from her stock option proceeds. In addition

to the money Chatel withheld, Carroll also sought statutory interest, attorney fees and

expenses, and compensatory damages for breach of the parties’ agreement.

At a bench trial, Carroll testified that she understood there could be additional

tax liability for exercising her stock options; but, that Chatel’s withholdings were

excessive; and she had requested Chatel provide her documentation regarding how

he determined the amount he withheld. Chatel testified he had consulted multiple

3 Section 13.04 of the agreement provided: “Each of the parties shall on demand execute and deliver to the other any . . . tax returns and other documents and do or cause to be done any other acts or such things which may be necessary or desirable to effectuate the provisions and purposes of this Settlement Agreement. If either party willfully fails on demand to comply with this provision, that party shall pay to the other all attorney’s fees, costs, and other expenses reasonably incurred as a result of such failure.” 4 Chatel filed a petition to modify his alimony obligation in 2018 due to a decrease in income. The trial court dismissed Chatel’s petition, and this Court denied his application for discretionary review.

4 accountants to determine the appropriate tax amount, but he admitted he did not

provide Carroll documentation of the withholdings.

Both Chatel and Carroll provided expert testimony from their accountants.

Carroll’s expert testified that divorce settlements usually direct how to calculate any

resulting tax liability, unlike the one at issue here. Carroll’s expert further estimated

that Chatel withheld an excess amount of $105,302. She further estimated that, had

Carroll been able to reinvest these proceeds into the stock market, she would have

earned an additional $350,207. She also calculated that Chatel owed Carroll $70,971

in statutory interest under OCGA § 7-4-12. On the other hand, Chatel’s expert

testified that Chatel assumed the proceeds from the sale would push him into a

different tax bracket, and he therefore withheld the difference between the percentage

his employer withheld and his new tax bracket. However, Chatel’s expert also stated

that this method could result in over-withholding because there was no guarantee

Chatel’s tax bracket would increase. Chatel’s expert opined that the over-withholding

totaled $33,095.

The trial court found Chatel in willful contempt for breach of the settlement

agreement due to the over-withholding and the failure to provide requested

documents. Accepting the testimony of Carroll’s expert, the court found Chatel owed

5 Carroll $105,302 from funds improperly withheld, plus $70,971 in statutory interest.

Further, the court assumed that Carroll would have invested the proceeds into the

stock market, and awarded $244,905 for unrealized investment profits. The trial court

also awarded Carroll $109,120 in attorney fees under OCGA § 19-6-2

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Bluebook (online)
Peter Chatel v. Leslie P. Carroll, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peter-chatel-v-leslie-p-carroll-gactapp-2023.