“Settlement agreements in matrimonial matters, being essentially consensual and voluntary in character, . . . [are] entitled to considerable weight with respect to their validity and enforceability in equity, provided they are fair and just.” Dolce v. Dolce, 383 N.J. Super. 11, 20 (App. Div. 2006) (quoting Petersen v. Petersen, 85 N.J. 638, 642 (1981)); see also Lepis v. Lepis, 83 N.J. 139, 153 (1980).

An agreement like a Property Settlement and Separation Agreement (PSSA) is favored by the “‘strong public policy favoring stability of arrangements’ in matrimonial matters.” Konzelman v. Konzelman, 158 N.J. 185, 193 (1999) (quoting Smith v. Smith, 72 N.J. 350, 360 (1977)). Accordingly, it is “approached with a predisposition in favor” of its “validity and enforceability.” Massar v. Massar, 279 N.J. Super. 89, 93 (App. Div.), certif. denied, 142 N.J. 455 (1995). However, a PSSA may only be validated to the extent that the agreement is consensual and voluntary, Konzelman, supra, 158 N.J. at 194, and comports with “equitable precepts.” Weishaus v. Weishaus, 180 N.J. 131, 143 (2004).

Marital property settlements agreements can only be enforced if they are fair to both parties because “‘contract principles have little place in the law of domestic relations.’” Conforti v. Guliadis, 128 N.J. 318, 323 (1992) (quoting Lepis, supra, 83 N.J. at 148). Nevertheless, matrimonial agreements such as the PSSA have long been recognized to be contractual in nature. Pacifico v. Pacifico, 190 N.J. 258, 265 (2007) (citing Massar, supra, 279 N.J. Super. at 93. “A basic principle of contract interpretation is to read the document as a whole in a fair and common sense manner.” Hardy ex. rel. Dowdell v. Abdul-Matin, 198 N.J. 95, 103 (2009). Moreover, “the law grants particular leniency to agreements made in the domestic arena,” which consequently gives “judges greater discretion when interpreting such agreements.” Guglielmo v. Guglielmo, 253 N.J. Super. 531, 542 (App. Div. 1992).

Additionally, “[a]s a general rule, courts should enforce contracts as the parties intended.” Pacifico, supra, 190 N.J. at 266. See also Tessmar v. Grosner, 23 N.J. 193, 201 (1957) (noting that the court’s role in interpreting a contract is to enforce the parties’ common intent). Moreover, the court is required to “consider what is written in the context of the circumstances at the time of drafting and to apply a rational meaning in keeping with the ‘expressed general purpose.’” Pacifico, supra, 190 N.J. at 266 (quoting N. Airlines, Inc. v. Schwimmer, 12 N.J. 293, 302 (1953)).

“The polestar of contract construction is to discover the intention of the parties as revealed by the language used by them.” Karl’s Sales & Serv., Inc., v. Gimbel Bros., Inc., 249 N.J. Super. 487, 492 (App. Div.), certif. denied, 127 N.J. 548 (1991). As such, the court should not re-write a contract or grant a better deal than that for which the parties expressly bargained. Solondz v. Kornmehl, 317 N.J. Super. 16, 21 (App. Div. 1998).

See related Blog Post, published in the New Jersey Family Law blog.

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

Under the three-prong test established in Marschall v. Marschall, 195 N.J. Super. 16, 29-31 (Ch. Div. 1984), and as clarified by Delorean v. Delorean, 211 N.J. Super. 432, 436-38 (Ch. Div. 1986), the proponent of an agreement must prove that there was: (1) no fraud or duress, (2) a lack of unconscionability, and (3) full and complete disclosure of financial wealth by the party looking to enforce the agreement. See Delorean, 211 N.J. Super. at 436-38.

Under the common law in New Jersey, an antenuptial agreement is generally valid “[s]o long as a spouse had sufficient opportunity to reflect on her actions, was competent, informed and had access to legal advice, and that of any relevant experts[.]”

Prior to the Legislature’s adoption of the Uniform Premarital Agreement Act (“UPAA”) in 1988, N.J.S.A. 37:2-31 to -41, the common law in New Jersey required that the proponent of such an agreement establish:

(1) that there be “full disclosure by each party as to his or her financial conditions;” (2) that the party sought to be bound by the agreement understood and accepted the terms and conditions of the agreement; and (3) that the agreement be fair and not unconscionable, that is, that the agreement will not “leave a spouse a public charge or close to it, or . . . provide a standard of living far below that which was enjoyed both before and during the marriage.”

[Rogers, supra, 404 N.J. Super. at 219 (quoting Marschall, supra, 195 N.J. Super. at 29-31).]

Our courts have embraced, for pre-Act cases, this three-part standard of Marschall, supra, as a “comprehensive exposition and analysis” of the law governing pre-Act agreements. D’Onofrio v. D’Onofrio, 200 N.J. Super. 361, 366 (App. Div.), certif. denied, 102 N.J. 366 (1985).

The UPAA specifically applies only to agreements “executed on and after [November 3, 1988].” N.J.S.A. 37:2-41. Therefore, any agreement executed prior to November 3, 1988 is governed by the common law of New Jersey. Rogers, supra, 404 N.J. Super. at 219.

“The easiest device [to ensure full disclosure] would probably be a schedule annexed to the agreement setting out, at least in general terms and with approximate values, the assets of the parties[,] as well as their income over the past few years.” Marschall, supra, 195 N.J. Super. at 33; see also Delorean, supra, 211 N.J. Super. at 438.

As stated in Marschall, “[a]n agreement which would leave a spouse a public charge or close to it, or which would provide a standard of living far below that which was enjoyed both before and during the marriage would probably not be enforced by any court.” Marschall, supra, 195 N.J. Super. at 30-31. (emphasis added). Marschall further noted that although “the applicable measure for judicially fixed support is the standard of living during the marriage, there does not seem anything inherently ‘unfair’ in an antenuptial agreement which uses a different standard?perhaps the somewhat lower standard at which one spouse lived before the marriage.” Id. at 31 (citing Lepis v. Lepis, 83 N.J. 139 (1980)).

As noted by Marschall, supra, 195 N.J. Super. at 30-31, considering a spouse’s standard of living prior to the marriage can be appropriate for evaluating a pre-Act agreement.

See related Blog Post, published in the New Jersey Family Law blog.

NOTE: My legal services include family law, divorce, child support, litigation, arbitration, mediation, child custody and visitation, alimony, equitable distribution, separation agreements, palimony, PSA, property settlement agreement, premarital and prenuptial agreements, midmarriage and marital agreements.

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When you are considering marriage, there are so many things to think about and discuss: assets, liabilities, earnings, in-kind contributions, child-rearing, chauffeur and other family services, home-maker; who is responsible for what; who owns what; who contributes what?

For one person’s experience, read: When Bankers Get Too Personal, by Nicole Collins, published in The New York Times.

Premarital mediation and a Pre-Nuptial Agreement may be helpful to some — if you agree, and you want to discuss this further, please call me for an appointment.

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

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1. What are your individual “financial ancestries.” Discuss your personal pasts — how did your parents deal with money, how does that impact how you deal with it, and how might that impact your relationship?

2. Catalog your past mistakes and overall money habits — review your credit reports, and discuss the loan payments you may have missed and the credit cards you may not need. Discuss what you have learned (or still need to learn) about handling money.

3. Discuss who will pay the bills each month. If one person is making most or all of the money, discuss whether that person will get to make most or all of the financial decisions? Even under the best of circumstances, it may be a good idea, at a minimum, to hold regular household meetings, complete with spreadsheets and financial statements, so that the both persons are up to speed on the state of family finances.

4. Discuss how rich do we want to be one day? Discuss your individual career paths — are they going to be something that pull you together? If it is a possibility (or probability) in your lives, discuss whether you are both O.K. with one of you acting essentially as a single parent, with the other partner working 80 hours a week until the age of 80?

Mediation may be the most comfortable medium for preparing for marriage — a mediator can help both of you to explore the key financial issues that may be your greatest obstacles during marriage.

NOTE: My legal services include family law, divorce, child support, litigation, arbitration, mediation, child custody and visitation, alimony, equitable distribution, separation agreements, palimony, property settlement agreements, premarital and prenuptial agreements, midmarriage and marital agreements.

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N.J.S.A. 37:2-38 squarely places the burden of proof to set aside a premarital agreement upon “the party alleging the agreement to be unenforceable.” Furthermore, the party must meet his or her burden by clear and convincing evidence. The grounds for challenge are enumerated in the statute and include equitable considerations, such as unconscionability of an agreement, failure to disclose and similar concerns. N.J.S.A. 37:2-38.

In this case, an ante-nuptial agreement states in the preamble that the agreement is “in lieu and in full discharge, settlement and satisfaction of any interest, rights and claims that otherwise each might have or could have, under the law, in and to the property and estate of the other, both before and after the other’s death.”

The section of the ante-nuptial agreement captioned “Mutual Waiver of Estate Rights” provides:
In the event of a separation or divorce and in the event of either party’s death, each party does hereby waive, relinquish, and release any and all right, claim or demand of every kind, nature and description he or she might otherwise acquire, or have at any time hereafter, in or against the estate of the other, by reason of any subsequent marriage to each other, including rights under community property laws, or as surviving spouse, whether by way of intestacy, dower or courtesy, or rights in the nature of intestacy, dower or courtesy, or any other right of the surviving spouse to share in the estate of the other or to receive any allowance or exemption from the estate of the other, or any right to elect to take against the will of the other under N.J.S.A. 3B:8-1 et seq. or any other similar statute, or the right to take an elective share pursuant to N.J.S.A. 3B:8-1 et seq. or any other similar statute, or the right to act as administrator or administratrix of the estate of the other.

The court held that the agreement, in this case, is applicable not only in the event of separation or divorce, but also in the event of a death while the parties were married and residing together.

See related Blog Post, published in the New Jersey Family Law blog.

NOTE: My legal services include family law, divorce, separation agreements, palimony, PSA, property settlement agreement, premarital and prenuptial agreements, midmarriage and marital agreements.

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New Jersey adopted the Uniform Pre-Marital Agreement Act (the Act), N.J.S.A. 37:2-31 to -41, in 1988. The Act expressly applies to agreements “executed on or after” the effective date of the Act and does not, therefore, apply to the parties’ 1981 agreement.

In Marschall v. Marschall, 195 N.J. Super. 16 (Ch. Div. 1984), the court distilled the prior case law and held definitively that prenuptial agreements were valid and enforceable and that “[s]uch agreements, subject to [certain] conditions . . . should be welcomed and encouraged.” Id. at 28. The court indicated that principles governing property settlement agreements “should be viewed as equally applicable to antenuptual agreements governing those same issues.” Ibid. (citing Petersen v. Petersen, 85 N.J. 638, 645-46 (1981)). The “conditions” under which prenuptial agreements would be deemed valid and enforceable evolved into a three prong test: (1) that there be “full disclosure by each party as to his or her financial conditions;” (2) that the party sought to be bound by the agreement understood and accepted the terms and conditions of the agreement; and (3) that the agreement be fair and not unconscionable, that is, that the agreement will not “leave a spouse a public charge or close to it, or . . . provide a standard of living far below that which was enjoyed both before and during the marriage.” Id. at 29-31.

The appellate court approved the Chancery Division’s “comprehensive exposition and analysis” in D’Onofrio v. D’Onofrio, 200 N.J. Super. 361, 366 (App. Div. 1985). There, the court indicated that alimony provisions in prenuptial agreements need not “cover all eventualities, since upon changes in circumstances a spouse may apply to the court for an appropriate modification.” Id. at 369-70 (citing Lepis v. Lepis, 83 N.J. 139, 158 (1980)).

[See related Blog Post, published in the New Jersey Family Law blog.]

Also see: “Prenuptial Agreements: Oxymoronic Under the Law; Support law is a slippery slope built on shifting sands“, published in the New Jersey Law Journal, June 22, 2009, p. 43 (196 N.J.L.J. 847).

And also: “PREMARITAL AGREEMENTS: THE F.A.I.R. WAY,” by Charles C. Abut, Esq.

See my related Blog Post on this case.

N.J.S.A. 3B:8-1 permits a surviving spouse to elect a right to take one-third of the augmented estate of a deceased spouse. That specific right, however, may be waived, in whole or in part, by written agreement. Specifically, N.J.S.A. 3B:8-10 expresses the Legislature’s intent that an elective share may be waived “by a written contract, agreement or waiver, signed by the party waiving after fair disclosure”.

Subsequently, in 1988, the Uniform Premartial Agreement Act, was enacted in this State, N.J.S.A. 37:2-31 to -41. This act defines more thoroughly than N.J.S.A. 3B:8-10 when a premarital agreement may be enforced, and it also governs all types of premarital agreements, not just those that contain a waiver of an elective share:

The burden of proof to set aside a premarital or pre-civil union agreement shall be upon the party alleging the agreement to be unenforceable. A premarital or pre-civil union agreement shall not be enforceable if the party seeking to set aside the agreement proves, by clear and convincing evidence, that:
a. The party executed the agreement involuntarily; or
b. The agreement was unconscionable at the time enforcement was sought; or
c. That party, before execution of the agreement:
(1) Was not provided full and fair disclosure of the earnings, property and financial obligations of the other party;
(2) Did not voluntarily and expressly waive, in writing, any right to disclosure of the property or finan-cial obligations of the other party beyond the disclosure provided;
(3) Did not have, or reasonably could not have had, an adequate knowledge of the property or financial obligations of the other party; or
(4) Did not consult with independent legal counsel and did not voluntarily and expressly waive, in writing, the opportunity to consult with indepen-dent legal counsel.
d. The issue of unconscionability of a premarital or pre-civil union agreement shall be determined by the court as a matter of law.
[N.J.S.A. 37:2-38.]

N.J.S.A. 37:2-38 provides greater detail than N.J.S.A. 3B:8-10 as to how the enforceability of a premarital agreement should be determined. Accordingly, it is fair to conclude that in this context the former has filled any gaps that may have existed in, and illuminates our understanding of, the more general terms of N.J.S.A. 3B:8-10. See Lewis v. Bd. of Trustees, Pub. Emp. Ret. Sys., 366 N.J. Super. 411, 417 (App. Div.) (quoting 2A Norman J. Singer, Sutherland Statutory Construction § 51:05 (6th ed. 2000)), certif. denied, 180 N.J. 357 (2004). This approach is particularly apt since N.J.S.A. 37:2-38 was enacted after N.J.S.A. 3B:8-10. See Maressa v. New Jersey Monthly, 89 N.J. 176, 195, cert. denied, 459 U.S. 907, 103 S. Ct. 211, 74 L. Ed.2d 169 (1982); Lewis, 366 N.J. Super. at 418.

A plaintiff bears the burden of presenting clear and convincing evidence of the requirements of these statutes. There is no material distinction between what N.J.S.A. 3B:8-10 refers to as “fair disclosure” and what N.J.S.A. 3B:2-38 describes as “full and fair disclosure.”

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For centuries the law in this State required that an agreement for the sale of an interest in land had to be reduced to writing, but the New Jersey statute of fraud was amended in 1996. See Morton v. 4 Orchard Land Trust, 180 N.J. 118, 126 (2004) (recognizing that the legislative commission recommending the change stated: “the focus of inquiry in a situation involving an agreement for the sale of an interest in real estate . . . should be whether an agreement has been made between the parties by which they intend to be bound.”). Hence, the applicable statute of frauds, more particularly, N.J.S.A. 25:1-13b, does not now require a signed writing to establish an agreement to transfer an interest in real estate or to hold an interest in real estate. It requires a higher standard of proof. The statute provides: “An agreement to transfer an interest in real estate or to hold an interest in real estate for the benefit of another shall not be enforceable unless:
. . .
b. a description of the real estate sufficient to identify it, the nature of the interest to be transferred, the existence of the agreement and the identity of the transferor and the transferee are proved by clear and convincing evidence.”

Further, and even before the statutory amendment, well-established principles relating to the statute of frauds and to the applicability of resulting trusts suggest that plaintiff’s claims were not necessarily foreclosed by the absence of a writing: “[I]t is a settled principle, that where one person purchases property for a stranger [to the deed], and the purchase money is paid by the stranger, or out of his funds, although the title is taken in the name of the person making the purchase, a trust results, and the land is held in trust for the party whose money is paid. This trust arises without any declaration in writing, for it is expressly excepted by the statute of frauds from the operation of that statute, and the facts, necessary to constitute such trust, may be provided by parol evidence. A similar rule prevails in cases where the consideration proceeds from two or more persons jointly. A resulting trust will arise in proportion to the amount of the consideration which they may have respectively contributed.” [Cutler v. Tuttle, 19 N.J. Eq. 549, 558 (E&A 1868); but see Yeiser v. Rogers, 19 N.J. 284, 288 (1955) (indicating that illegality of purpose may preclude enforcement of a resulting trust that might otherwise arise)].

Finally, in order to prevail on an action for unjust enrichment, the plaintiff must “’show both that defendant received a benefit and that retention of that benefit without payment would be unjust.’” Caputo v. Nice-Pak Prods., Inc., 300 N.J. Super. 498, 507 (App. Div.), certif. denied, 151 N.J. 463 (1997) (quoting VRG Corp. v. GKN Realty Corp., 135 N.J. 539, 554 (1994)).

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union Co. NJ.

The basic contractual nature of matrimonial agreements has long been recognized. Harrington v. Harrington, 281 N.J. Super. 39, 46 (App. Div. 1995)(citing Peterson v. Peterson, 85 N.J. 638, 642 (1981); Massar v. Massar, 279 N.J. Super. 89, 93 (App. Div. 1995)), certif. denied, 142 N.J. 455 (1995). At the same time, “the law grants particular leniency to agreements made in the domestic arena,” thus allowing “judges greater discretion when interpreting such agreements.” Guglielmo v. Guglielmo, 253 N.J. Super. 531, 542 (App. Div. 1992).

As a general rule, courts should enforce contracts as the parties intended. Henchy v. City of Absecon, 148 F. Supp.2d 435, 439 (D.N.J. 2001); Kampf v. Franklin Life Ins. Co., 33 N.J. 36, 43 (1960). Similarly, it is a basic rule of contractual interpretation that a court must discern and implement the common intention of the parties. Tessmar v. Grosner, 23 N.J. 193, 201 (1957). The court’s role is to consider what is written in the context of the circumstances at the time of drafting and to apply a rational meaning in keeping with the “expressed general purpose.” Northern Airlines, Inc. v. Schwimmer, 12 N.J. 293, 302 (1953); accord Dontzin v. Myer, 301 N.J. Super. 501, 507 (App. Div. 1997).

The Restatement Second of Contracts § 204 provides “[w]hen the parties to a bargain sufficiently defined to be a contract have not agreed with respect to a term which is essential to a determination of their rights and duties, a term which is reasonable in the circumstances is supplied by the court.” Restatement (Second) of Contracts § 204 (1981)(emphasis added). As that section and its commentary reveal, it is intended to be applied in cases in which the parties failed to agree regarding an issue, generally because they did not anticipate that it would arise or merely overlooked it. Id. § 204 cmts. (1981).

When a contract term is ambiguous, that rule of contract interpretation requires a court to adopt the meaning that is most favorable to the non-drafting party. See 5 Corbin on Contracts § 24.27 (Perillo ed., rev. ed. 1998). The doctrine may be utilized after a court has examined the terms of the contract, in light of the common usage and custom, and considered the circumstances surrounding its execution. If, at that time, the court is unable to determine the meaning of the term, contra proferentem may be employed as a doctrine of last resort. See ibid. The rationale behind that method of interpretation is that “[w]here one party chooses the term of a contract, he is likely to provide more carefully for the protection of his own interests than for those of the other party. He is also more likely than the other party to have reason to know of uncertainties of meaning.” Ibid. Importantly, contra proferentem is only available in situations where the parties have unequal bargaining power. Ibid. If both parties are equally “worldly-wise” and sophisticated, contra proferentem is inappropriate. See RCI Northeast Servs. Div. v. Boston Edison Co., 822 F.2d 199, 203 n.3 (1st Cir. 1987).

Even if one lawyer had drafted the PSA, the doctrine of contra proferentem is inapposite if a prerequisite to its application – unequal bargaining power – did not exist.

NOTE: My legal and mediation services are offered to Polish-speaking and other clients in Old Bridge 08857; Perth Amboy 08861; Sayreville 08871; South Amboy 08878; South River 08877; Avenel 07001; Colonia 07067; Iselin 08830; Woodbridge 07095; Somerset 08873; Somerville 08876 and Watchung 07069, New Jersey.

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Where the parties decide to engage in voluntary mediation in order to avoid the costs and expenses related to counsel and litigation, a party’s failure to retain counsel cannot be held against her, particularly where the parties have a contractual and moral obligation to be open and honest. Mediation is intended to be a joint effort to amicably resolve the dissolution of the parties’ marriage and to do so at minimal cost. A property settlement agreement resulting from a voluntary mediation, like any privately negotiated PSA, may be reformed where there is unconscionability, fraud, or mistake and concealment. Indeed, there may be more reason to apply the principle in this context, since a mediator has no authority to compel disclosure and the process is dependent upon the candor and forthrightness of the parties.

Private mediations must remain confidential or they will have no beneficial impact. State v. Williams, 184 N.J. 432, 444-52 (2005) (stating in dictum that the criminal defendant’s need for the mediator’s testimony did not outweigh the need for confidentiality); Lehr v. Afflito, 382 N.J. Super. 376, 395 (App. Div. 2006) (in mediation conducted under court rule, R. 1:40-5, confidentiality required by R. 1:40-4(c) “did not substantially outweigh the private and public interests in protecting confidentiality”). There is no basis for distinguishing between uncounselled mediated agreements and other types of PSAs in terms of evaluating conscionability.

Courts possess the equitable authority to modify privately negotiated property settlement agreements. Conforti v. Guliadis, 128 N.J. 318, 323 (1992). This is because such agreements “must reflect the strong public and statutory purpose of ensuring fairness and equity in the dissolution of marriages.” Miller v. Miller, 160 N.J. 408, 418 (1999). While spousal agreements are presumed valid, only those agreements that are “fair and just” will be enforced. See Petersen v. Petersen, 85 N.J. 638, 642 (1981). A spousal agreement may be reformed when it is “unconscionable,” “it is the product of fraud or overreaching by a party with power to take advantage of a confidential relationship,” Dworkin v. Dworkin, 217 N.J. Super. 518, 523 (App. Div. 1987), or when, due to “common mistake[] or mistake of one party accompanied by concealment of the other, the agreement fails to express the real intent of the parties[.]” Miller, supra, 160 N.J. at 419.

The Uniform Mediation Act (”UMA”), N.J.S.A. 2A:23C-1 to -13, applies to mediations required “by statute, court rule or administrative agency rule, or []referred to mediation by a court, administrative agency, or arbitrator[.]” N.J.S.A. 2A:23C-3(a)(1). If an agreement was entered into after the statute was enacted, the UMA would apply by virtue of the parties’ agreement. See N.J.S.A. 2A:23C-3(a)(2),(3).

N.J.S.A. 2A:23C-5(a) provides that the confidentiality attaching to a mediation may be waived only if all of the parties to the mediation “expressly” agree to the waiver. However, the UMA provides exceptions to the broad rule of section 5(a), reflecting our present public policy and providing that “[t]here is no privilege . . . if a court . . . . finds, after a hearing in camera, that the party seeking discovery or the proponent of the evidence has shown that the evidence is not otherwise available, that there is a need for the evidence that substantially outweighs the interest in protecting confidentiality, and that the mediation communication is sought or offered in: . . . . (2) . . . a proceeding to prove a claim to rescind or reform or a defense to avoid liability on a contract arising out of the mediation.” [N.J.S.A. 2A:23C-6(b).]

But even then, “[a] mediator may not be compelled to provide evidence of a mediation communication[.]” N.J.S.A. 2A:23C-6(c). See also N.J.S.A. 2A:23C-2 (definition of “mediation communication”).

NOTE: My legal and mediation services are offered to clients in Union, Middlesex, Somerset, Essex, Hudson, Bergen, and Morris counties in NJ.

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