Phibbs v. Phibbs

Superior Court of Guam·Decided June 24, 2014·No. DM0006-14·Unknown

Opinion

I 2014 JUN 24 PK 4: 34 2

3 Rifx'O COURT 4

5 IN THE SUPERIOR COURT OF GUAM 6

8 DOMESTIC CASE NO. DM 0006-14 Plaintiff, 9 V. 10 DECISION AND ORDER PETER F. PHIBBS, 11

12 Defendant. 13

16 This matter came before the Honorable Arthur R. Barcinas on the 2°d day of May, 2014,

17 for hearing on the Defendant' s Motion to Dismiss. Attorney Ron Moroni represents the Plaintiff 18 in this matter, and Attorney Jeffrey A. Cook represents the Defendant. Without oral argument, 19

20 the Court took the motion under advisement on the briefings. For the reasons set forth below,

21 the Defendant's Motion to Dismiss is DENIED. 22 BACKGROUND 23 The Plaintiff Shannon H. Phibbs and the Defendant Peter F. Phibbs were married in 24 Denver, Colorado, on April 17, 2005. They have a daughter, Savannah Rae Phibbs, born on 25

26 August 17, 2004 in Denver, Colorado. At the time of the marriage, the Plaintiff was studying

27 medicine and the Defendant was their daughter' s primary caretaker. The Plaintiffs medical 28 school tuition was paid for by the United States Navy, and she has served in the Navy since her Decision and Order DM0006-14; Phibbs v. Phibbs

graduation. The parties moved to Guam in 2011 as part of the Plaintiff's service to the Navy. 1

2 On February 28, 2013, with the aid of Christina D. Oliver, a lawyer and notary in service with

3 the U.S. Navy, the parties executed a Separation Agreement. The Separation Agreement 4 purported to settle certain matters between the parties pending a divorce. These included 5 disposition of property and debts, child custody and support, and maintenance. The Separation 6

7 Agreement also included a term (hereinafter called the "covenant not to divorce") in which the

8 Plaintiff Shannon H. Phibbs agreed to refrain from filing for divorce until she resigned from the

9 Navy's service. At the time the Agreement was executed, this was projected to be October 10 2015. 11 On January 6, 2014, the Plaintiff filed a Complaint for the Dissolution of Marriage. The 12

13 Defendant made a motion to dismiss the complaint on February 11, arguing that the covenant

14 not to divorce barred the dissolution action. The Plaintiff filed an Opposition to the motion on 15 March 10, arguing that enforcement of the covenant not to divorce was contrary to public policy 16 and also that any damages resulting to the Defendant from the divorce could be adequately 17 compensated with money. The Defendant filed a Reply on March 24. 18

20 Paragraph 22 of the parties' Separation Agreement, which contains the covenant not to 21 divorce, reads as follows: 22 Separation agreement is for legal/financial protection to the wife while allowing 23 husband to retain certain benefits to include medical insurance. Wife agrees to 24 delay divorce filing until separating from the Navy (projected October 2015) so long a s husba nd r ema ins in good faith standing with current agreement and 25 custody-related issues. Spousal support of $400/month would continue until this time as well, to be renegotiated vs terminated in the setting o f a divorce 26 agreement. 27 Def.'s Ex. A ¶ 22, Feb. 11, 2014. 28

Page 2 of 15 Decision and Order DM0006-14; Phibbs v. Phibbs

The Separation Agreement also contains a choice of law clause, choosing Colorado law. 1

2 It reads as follows: "The law of the State of Colorado will govern the interpretation of this

3 agreement, and the status, ownership, and division of property between the parties wherever 4 either or both of them may from time to time reside." Def.'s Ex. A ¶ 35, Feb. 11, 2014. 5 The basis for the Defendant's Rule 12(b)(6) motion is the argument that the Plaintiff has 6 contracted away her right to file for divorce until she resigns from service in the U.S. Navy, that 7

8 such a contractual provision is not void for public policy, and that this Court should enforce it.

9 In order to determine the validity of the covenant not to divorce, the Court first analyzes choice 10 of law to determine which jurisdiction's law to apply. 11 1. Choice of Law 12 The Supreme Court of Guam has not yet squarely addressed Guam's approach to choice 13

14 of law clauses in marital separation agreements. However, in Banes v. Superior Court Banes),

15 the Supreme Court implied that the parties' choice of the Commonwea lth of the Nor ther n 16 Marianas' law in a prenuptial agreement was valid: "Facing final judgment in Guam while 17 another divorce matter is concurrently proceeding in the CNMI, and the potential for 18

19 inconsistent interpretations of the CNMI law provided by the choice of law provision in the

20 Prenuptial Agreement are among the problems that David cite as `irreparable harm."' Banes v. 21 Superior Court (Banes), 2012 Guam 11115. The Supreme Court agreed with David Banes that 22 the Superior Court lacked personal jurisdiction, and in issuing the requested writ of prohibition 23 did not rule that there could be no inconsistent interpretation of CNMI law because such a 24

25 choice of law clause was invalid in Guam courts. See Banes, 2012 Guam 11 ¶¶ 56-57.

26 The Restatement (Second) of Conflict of Laws generally favors upholding explicit 27 choice of law clauses in contracts: "[T]he original Restatement did not acknowledge any power 28

Page 3 of 15 Decision and Order DM0006-14; Phibbs v. Phibbs

in the parties to choose the applicable law. The present Chapter recognizes that the parties have 1

2 such power subject to certain limitations." Restatement (Second) of Conflict of Laws Ch. 8,

3 Introductory Note (1971). Section 187 of the Restatement addresses the validity of contractual 4 choice of law clauses. It begins with: "The law of the state chosen by the parties to govern their 5 contractual rights and duties will be applied if the particular issue is one which the parties could 6 have resolved by an explicit provision in their agreement directed to that issue." Restatement 7

8 (Second) of Conflict of Laws § 187(1) (1971). Even if the issue could not be resolved by an 9 explicit provision, the chosen law will still be upheld unless either: 10 "(a) the chosen state has no substantial relationship to the parties or the 11 transaction and there is no other reasonable basis for the parties' choice, or (b) application of the law of the chosen state would be contrary to a fundamental 12 policy of a state which has a materially greater interest than the chosen state in the 13 determination of the particular issue and which, under the rule of § 188, would be the state of the applicable law in the absence of an effective choice of law by the 14 parties."

15 Id. § 187(2) (1971). 16 In determining which law applies to interpret a contract that lacks an effective choice of 17 law clause, the court must look to: "(a) the place of contracting, (b) the place of negotiation of 18

19 the contract, (c) the place of performance, (d) the location of the subject matter of the contract,

20 and (e) the domicil, residence, nationality, place of incorporation, and place of business of the 21 parties." Id. § 188(2) (1971). 22 Here, the particular issue to which the choice of law analysis refers is the same as the 23 question ultimately at issue in the Defendant's motion: whether the covenant not to divorce is 24

25 enforceable, as the Defendant argues, or whether it is void, as the Plaintiff argues. Contrast

26 Def.'s Reply 5, Mar. 24, 2014, with Pl.'s Opp. 2-4, Mar. 10, 2014. The Restatement's official 27 comment on § 187(1) clarifies that it is a rule enabling the parties to incorporate a jurisdiction's 28

Page 4 of 15 Decision and Order DM0006-14; Phibbs v. Phibbs

law by reference into their agreement, but it is not a rule by which a court conducts a choice of 1

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