Sosnoski v. Sosnoski

24 Pa. D. & C.5th 100
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedApril 20, 2011
DocketNo. 11159 of 2004, C.A.
StatusPublished

This text of 24 Pa. D. & C.5th 100 (Sosnoski v. Sosnoski) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sosnoski v. Sosnoski, 24 Pa. D. & C.5th 100 (Pa. Super. Ct. 2011).

Opinion

HODGE, J.,

This case was before the court on September 20, 2010 for a hearing on a petition for contempt and enforcement of marital settlement agreement filed on behalf of the plaintiff, Shirley Sosnoski (hereinafter “wife”). After a complete hearing was held before the court, counsel for the parties were ordered to submit to the court memorandums of law relative to the factual and legal issues presented at the hearing. Counsel has complied with the court’s request and the matter is fit for the court to make a determination.

A brief summary of the relevant factual background can be summarized as follows: A complaint in divorce was filed on September 18, 2004. On July 18,2006, the parties entered into a marital settlement agreement (hereinafter “MSA”). However, the same was never filed by plaintiff’s counsel, and on January 16, 2007 a motion to compel compliance with marital settlement agreement was filed on behalf of the defendant, Martin Sosnoski (hereinafter “husband”). An order of court was subsequently issued directing wife’s counsel to filed the MSA, wife’s affidavit of consent and wife’s waiver of notice of intention to request entry of divorce decree under Section 3301(c) of the Divorce Code pursuant to the Pennsylvania Divorce Code. Husband was further ordered to pay wife $7,000 [102]*102for her interest in a 1971 Corvette owned by the parties. Wife’s counsel complied with the directions of the court; however husband had not paid wife the $7,000 as directed. On February 8, 2007, the court entered a decree in divorce.

On May 14, 2007 a petition for contempt and special relief was filed on behalf of wife. In her petition, wife alleged that there were still outstanding obligations/ requirements of husband under the MSA and specific relief based on husband’s failure to comply with the MSA. The court then entered a rule to show cause upon husband and scheduled a hearing. An answer was filed by husband and a hearing was held on June 8, 2007.

Prior to the court issuing an order from the June 8,2007 hearing, plaintiff filed a motion for emergency special relief. In the motion, plaintiff alleged irreparable injury pending the court’s determination and sought injunctive relief whereby husband was prohibited from further dissipating marital assets as well as reimbursement for attorney’s fees associated with her attempts to enforce the parties’ MSA. The court again entered a rule to show cause upon husband and scheduled a hearing for May 30, 2008. Husband responded by filing an answer and new matter asserting that wife has not complied with the MSA and seeking attorney’s fees and reimbursement for other costs.

To complicate matters further, the transcript for the hearing held on June 8,2007 was damaged beyond repair, and the court was forced to schedule a re-hearing on the petition for contempt and special relief. After multiple [103]*103continuances requested by both sides and on the court’s own motion, a second hearing was finally held on September 20, 2010.

In Pennsylvania, a settlement agreement between a husband and wife is governed by the law of contracts, unless the agreement itself provides otherwise. Caccavo v. Caccavo, 565 A.2d 1199 (Pa. Super. 1989); Sonder v. Sonder, 549 A.2d 155 (1988). Hence, when the language of such an agreement is clear and unambiguous, the focus of the interpretation must be upon the terms as manifestly expressed. Caccavo, supra, 565 A.2d at 1202. The standard of enforceability of a contractual agreement is also clear: “[a]bsent fraud, misrepresentation, or duress, spouses should be bound by the terms of their agreements.” McMahon v. McMahon, 612 A.2d 1360, 1363 (Pa. Super. 1992) (citations omitted). As such, a trial court may interpret a marital settlement agreement like a contract, but the court has neither the power nor the authority to modify or vary the decree unless there is conclusive proof of fraud or mistake. Bianchi v. Bianchi, 859 A.2d 511,515 (Pa. Super. 2004).

When construing agreements involving clear and unambiguous terms, a trial court need only look to the writing itself to give effect to the parties’ understanding. Vaccarello v. Vaccarello, 563 Pa. 93, 101, 757 A.2d 909, 913-914 (Pa. 2000). A court may not modify the plain meaning of the words under the guise of interpretation. Id. In addition, this court must consider such contracts without reference to matters outside of the document, and we must ascertain the parties’ intentions when entering into the contract from the entire instrument. Purdy v. [104]*104Purdy, 715 A.2d 473, 475 (Pa. Super. 1998). Additionally, the parties are bound “without regard to whether the terms were read and folly understood and irrespective of whether the agreements embodied reasonable or good bargains.” Sabad v. Fessenden, 825 A.2d 682, 688 (Pa. Super. 2003).

After a careful review of the MSA, the court notes that both parties were represented by counsel and entered into this agreement freely. Each committed to abiding by the terms thereof and in doing so agreed not only to devise a plan for payment of outstanding debt but also to relinquish all other interest in each other’s property. The validity of the MSA was finalized when it was originally incorporated in the divorce decree and no appeal asserting fraud or mistake in the execution of the MSA was taken subsequent to it being filed. As such the MSA is deemed valid. Jackson V. Culp, 583 A.2d 1236, 1239 (Pa. Super. 1990); Sonder v. Sonder, 549 A.2d 155, 159 (Pa. Super. 1988); Litwack v. Litwack, 433 A.2d 514, 516 (Pa. Super. 1981). The court now looks to determine whether either party has willfully failed to comply with the terms of the agreement.

In 1988, Section 3105(a) of the Divorce Code was amended to read as follows:

“(a) Enforcement. —A party to an agreement regarding matters within the jurisdiction of the court under [the Divorce Code], whether or not the agreement has been merged or incorporated into the decree, may utilize a remedy or sanction set forth in [the Divorce Code] to enforce the agreement to the same extent as though [105]*105the agreement had been an order of the court except as provided to the contrary in the agreement.”

Courts have consistently utilized Section 3105 to enforce marital settlement agreements through a civil contempt complaint regardless of whether or not the agreement has been incorporated or merged into, or reduced to, an order. See, e.g., McGinnis v. McGinnis, 654 A.2d 563 (Pa. Super. 1995); Jackson v. Culp,

Related

Nagle v. Nagle
799 A.2d 812 (Superior Court of Pennsylvania, 2002)
Drake v. Drake
725 A.2d 717 (Supreme Court of Pennsylvania, 1999)
Sabad v. Fessenden
825 A.2d 682 (Superior Court of Pennsylvania, 2003)
Caccavo v. Caccavo
565 A.2d 1199 (Supreme Court of Pennsylvania, 1989)
Sutliff v. Sutliff
543 A.2d 534 (Supreme Court of Pennsylvania, 1988)
McMahon v. McMahon
612 A.2d 1360 (Superior Court of Pennsylvania, 1992)
Jackson v. Culp
583 A.2d 1236 (Supreme Court of Pennsylvania, 1990)
Vaccarello v. Vaccarello
757 A.2d 909 (Supreme Court of Pennsylvania, 2000)
McGinnis v. McGinnis
654 A.2d 563 (Superior Court of Pennsylvania, 1995)
Purdy v. Purdy
715 A.2d 473 (Superior Court of Pennsylvania, 1998)
Sonder v. Sonder
549 A.2d 155 (Supreme Court of Pennsylvania, 1988)
Litwack v. Litwack
433 A.2d 514 (Superior Court of Pennsylvania, 1981)
Bianchi v. Bianchi
859 A.2d 511 (Superior Court of Pennsylvania, 2004)

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Bluebook (online)
24 Pa. D. & C.5th 100, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sosnoski-v-sosnoski-pactcompllawren-2011.