Rebecca E Chew v. Joseph P Lopez

CourtMichigan Court of Appeals
DecidedApril 25, 2024
Docket366641
StatusUnpublished

This text of Rebecca E Chew v. Joseph P Lopez (Rebecca E Chew v. Joseph P Lopez) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rebecca E Chew v. Joseph P Lopez, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

REBECCA E. CHEW, formerly known as UNPUBLISHED REBECCA E. LOPEZ, April 25, 2024

Plaintiff-Appellee,

v No. 366641 Clinton Circuit Court JOSEPH P. LOPEZ, LC No. 21-030034-DO

Defendant-Appellant.

Before: M. J. KELLY, P.J., and JANSEN and MURRAY, JJ.

PER CURIAM.

Defendant appeals as of right the trial court’s order granting defendant attorney fees and costs and denying him interest in this divorce action from plaintiff. Defendant argues that the trial court abused its discretion in its attorney fee award without following the proper framework, and that he should have been granted interest on delayed property settlement payments in equity. We vacate the trial court’s award of attorney fees, and remand for an appropriate determination, and affirm the denial of postjudgment interest.

I. BACKGROUND FACTS AND PROCEDURAL HISTORY

The parties were married in June 1990, and lived together until May 1, 2021. They had adult children at the time that plaintiff filed for divorce on June 18, 2021, alleging a breakdown in the marriage. The parties reached a full settlement regarding the division of marital property during mediation, and entered a consent judgment of divorce on May 31, 2022. Plaintiff was awarded all interest in her business, Better Health Therapy Center. The consent judgment required plaintiff to pay defendant a property settlement of $95,000 within 90 days of entry of the order. It also provided that the parties would be entitled to attorney fees if they had to seek enforcement of the consent judgment.

When plaintiff failed to make the lump-sum payment by September 1, 2022, defendant moved to enforce the consent judgment, appoint a receiver, and for attorney fees and interest. Plaintiff moved for relief from judgment, asserting she was unable to make the lump-sum payment

-1- without obtaining financing, which she was denied from three banks because of a delinquent credit card in defendant’s name. She sought court approval of a payment plan to pay defendant $1,500 each month until she obtained financing or paid in full. During discovery, defendant learned that plaintiff had a sufficient amount in her business account to pay the property settlement, and the court granted his ex parte motion to freeze the account. At a hearing held on December 13, 2022, the court ordered plaintiff to pay defendant $75,000 by December 16, 2022, after which the court would lift the freeze on her account, and to make the $1,500 monthly payment to defendant by January 3, 2023, February 1, 2023, and March 1, 2023. The parties were also directed to file supplemental briefs on the issues of damages, interest, and attorney fees.

Defendant argued that he was entitled to postjudgment interest in equity, $4,367 in damages because he lost a prepaid scuba trip and incurred late fees on paying off his vehicle from plaintiff’s failure to pay the property settlement on time, and that he was entitled to $13,764 in attorney fees for all of the postjudgment work. Plaintiff responded that defendant was not entitled to interest and his request for attorney fees was not reasonable. The evidentiary hearing began on March 2, 2023, with Melissa Leckie testifying as a stipulated expert in family law. She testified that for an attorney with the same years of experience as defense counsel, the appropriate hourly rate was $250 per hour, and that she would have charged 10 hours of work on this postjudgment matter. Both parties testified, and the only exhibits admitted at trial were the denial letters from three banks when plaintiff sought financing. At the end of the hearing, plaintiff was ordered to pay defendant the remaining balance on the property settlement, $8,569.04, by March 10, 2023, which she paid in full.

The court found plaintiff’s motion for relief moot because she paid the remaining balance of the property settlement, so a payment plan was no longer needed. Similarly, defendant’s request to appoint a receiver was moot. The court denied defendant’s request for damages, as well as his motion for interest because there was no evidence presented at the hearing about interest. The court found an award of attorney fees to defendant appropriate under the enforcement provision of the consent judgment and MCR 3.206(D)(2)(b) (where a party fails to comply with a court order despite the ability to do so). However, the only evidence at trial established that a $250 hourly rate for 10 hours of work was reasonable, so the court awarded defendant $2,500 in attorney fees plus a $20 filing fee. Defendant now appeals.

II. ATTORNEY FEES

Defendant argues that the trial court abused its discretion in finding $2,500 in attorney fees was reasonable without following the applicable framework. We agree.

This Court reviews a trial court’s award of attorney fees and costs for an abuse of discretion. Pirgu v United Servs Auto Ass’n, 499 Mich 269, 274; 884 NW2d 257 (2016). A trial court abuses its discretion when its decision is outside the range of reasonable and principled outcomes. Id.

Attorney fees are generally not recoverable as an element of costs or damages absent an express legal exception. Fleet Business Credit v Krapohl Ford Lincoln Mercury Co, 274 Mich App 584, 589; 735 NW2d 644 (2007). Exceptions are narrowly construed, and one exception exists where attorney fees are provided by contract of the parties. Id. “[A] contractual clause

-2- providing that in the event of a dispute the prevailing party is entitled to recover attorney fees is valid.” Id. Here, the provision of attorney fees was expressly provided in paragraph 58 of the parties’ consent judgment of divorce:

58. IT IS FURTHER ORDERED in the event either party is called upon to seek enforcement of any of the terms of this Consent Judgment of Divorce or is required to retain counsel to secure the implementation of the terms of this Consent Judgment of Divorce or if either party defaults in the performance of any obligations set forth in this Consent Judgment of Divorce, the prevailing party shall be entitled to an award of all expenses, including reasonable and actual attorney fees and costs, incurred in connection with any enforcement proceedings.

“Consent judgments of divorce are contracts and treated as such.” Andrusz v Andrusz, 320 Mich App 445, 452; 904 NW2d 636 (2017).

In Smith v Khouri, 481 Mich 519, 529-530; 751 NW2d 472 (2008), our Supreme Court recognized that trial courts historically weighed the factors in Wood v Detroit Auto Inter-Ins Exchange, 413 Mich 573; 321 NW2d 653 (1982), and MRPC 1.5(a) to determine a reasonable attorney fee, and provided the following framework:

We hold that a trial court should begin its analysis by determining the fee customarily charged in the locality for similar legal services, i.e., factor 3 under MRPC 1.5(a). In determining this number, the court should use reliable surveys or other credible evidence of the legal market. This number should be multiplied by the reasonable number of hours expanded in the case (factor 1 under MRPC 1.5(a) and factor 2 under Wood). The number produced by this calculation should serve as the starting point for calculating a reasonable attorney fee. We believe that having the trial court consider these two factors first will lead to greater consistency in awards. Thereafter, the court should consider the remaining Wood/MRPC factors to determine whether an up or down adjustment is appropriate. And, in order to aid appellate review, a trial court should briefly discuss its view of the remaining factors. [Smith, 481 Mich at 530-531.]

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Related

Smith v. Khouri
751 N.W.2d 472 (Michigan Supreme Court, 2008)
Lawrence v. Lawrence
388 N.W.2d 291 (Michigan Court of Appeals, 1986)
Wood v. Detroit Automobile Inter-Insurance Exchange
321 N.W.2d 653 (Michigan Supreme Court, 1982)
Fleet Business Credit, LLC v. Krapohl Ford Lincoln Mercury Co.
735 N.W.2d 644 (Michigan Court of Appeals, 2007)
Olson v. Olson
729 N.W.2d 908 (Michigan Court of Appeals, 2007)
Ashbrenner v. Ashbrenner
401 N.W.2d 373 (Michigan Court of Appeals, 1986)
Reigle v. Reigle
474 N.W.2d 297 (Michigan Court of Appeals, 1991)
Pirgu v. United Services Automobile Association
884 N.W.2d 257 (Michigan Supreme Court, 2016)

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Rebecca E Chew v. Joseph P Lopez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-e-chew-v-joseph-p-lopez-michctapp-2024.