Legislation Watch
February 5, 2015 § 6 Comments
Here is a list of bills that may affect chancery court practice, are still pending before the legislature, and are “not dead” as of 2-3-15:
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Rule against perpetuities; revise with respect to certain trusts. |
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Estates; provide for a statutory order of abatement for shares of distributees of property of a deceased. |
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Foreign executor or administrator; revise authority of financial institutions to turn over property or funds of a decedent to. |
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Conservator; allow appointment for a single transaction. |
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Courts; prohibit from applying foreign law under certain circumstances. |
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Divorce; revise habitual cruel and inhuman treatment to include verbal, emotional or psychological abuse. |
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Commercial Real Estate Broker Lien Act; clarify definition of “commercial real estate” under. |
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Title disputes; clarify jurisdiction of state courts in certain. |
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Domestic violence; revise procedures related to. |
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Child abuse; clarify mandatory reporting by school officials. |
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Child neglect; add children left alone in motor vehicles to definitions of. |
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Estate bond requirement; authorize court or chancellor to waive. |
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HB 703 |
Judicial redistricting; revise. |
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Visitation rights; amend Grandparents’ Rights Law to include great-grandparents. |
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Suits against the state; Supreme Court to have original jurisdiction for claims seeking injunctive relief. |
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Landlord-tenant; provide for disposition of personal property remaining on the premises after removal of the tenant. 01/28 (H) Title Suff Do Pass |
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HB 713 |
Mississippi Private Investigation Regulatory Act; create. |
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Property Insurance Clarity Act; create. |
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Court reporters; increase salary for those in circuit, chancery and county courts. |
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HB1101 |
Professional privilege tax; impose on persons who practice in state and who are not domiciled in and do not maintain regular place of business in state. |
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HB1319 |
Marshals and constables; revise fees charged for service of process. |
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Domestic violence; clarify entry of criminal protection orders in the registry. |
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False report of child abuse or neglect; provide criminal penalties and civil liability. |
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Visitation; allow to third party under certain limited circumstances. |
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Civil commitment; include nurse practitioners as authorized evaluators. |
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Children in custody of DHS; require notification of parents of child’s siblings in conformity with federal law. |
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Child support; may continue past age of majority for a disabled child. |
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Court reporters; increase annual salary of. |
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SB2231 |
Constables; revise fees charged for service of process. |
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Easements; clarify purchase of for access. |
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Uniform Interstate Family Support Act; create (corrected). |
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Mississippi Uniform Limited Partnership Act; revise and expand. |
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Real property liens; clarify Notice of Contest of Lien form. |
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SB2390 |
Service of process; sheriff may retain fee for attempt to serve. |
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SB2542 |
Limited liability companies; delete repeal clause on fees. |
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Legal proceeding; child witness to receive accommodations. |
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Trial courts; redistrict. |
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Mourn the loss and commend the life and public service of former Senator and Judge Ray Montgomery. |
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Mourn the loss and pay tribute to the judicial leadership of former Mississippi Supreme Court Chief Justice Roy Noble Lee. |
A Higher Duty
February 4, 2015 § 5 Comments
Many lawyers get into the mindset that winning is the most important thing, and it shows up in their take-no-prisoners, no-holds-barred, Rambo-ish approach to litigation. Discovery is adversarial and contested, sanctions are threatened at the slightest slight, and aggressive motion practice is used like a jousting match of yore.
Those lawyers point to the duty in our professional rules to represent the client zealously, within the bounds of the law. The emphasis, though, is on zeal.
Consider, however, this scenario:
You are representing a young mother in a custody contest. Her former husband is trying to get custody of their 3-year-old son, who has had bruises on his legs, and who has nightmares and is a bedwetter. The father knows something is wrong, and as discovery proceeds it is apparent that he does not have enough solid information to make a case of change in circumstances and adverse effect. The court has not appointed a GAL because the allegations to this point do not warrant it. You, however, learn as the case goes on that your client had a live-in boyfriend who did, indeed, whip the child. The boyfriend is a convicted felon with a violent history, and your client is afraid of him. The other side knows nothing about this, and has not even asked anything in discovery that your client had to lie about to conceal the information. When you confront her with the new-found information, she admits it, but assures you that she made the boyfriend leave during the litigation, although he has made it clear that he will return when the case is over.
What do you do? On the one hand, if you voluntarily disclose the information without a specific discovery request for it, you will have violated your client’s confidentiality. And the Rambo in you has to acknowledge that it will surely send the case plummeting from its heights as a sure winner to the depths of loserdom. On the other hand, it certainly does not seem like it’s in the best interest of the child to be in the mother’s home with that violent boyfriend, and you know your chancellor well enough to know that if those facts came to light, she would not hesitate to protect the child.
The highest and most serious duty of a chancellor is to do what is in the best interest of a child. The best interest of the child is always the “polestar consideration” in every custody and child-affecting decision in chancery court. The rules of evidence do not trump that responsibility, nor do considerations of winning and losing, attorney-client privilege, or anything else.
As an officer of the court, you may not do anything that thwarts the court in its duty. You may not stifle the truth in such matters, or suppress evidence, or do anything that will result in compromising the safety of a child.
So how can you act and still maintain the confidentiality of your client? If I were the attorney, I would file a motion for appointment of a GAL. No details need to be pled. You could recite that the father’s suspicions should be investigated for the best interest of the child, and leave it at that. A competent GAL will ferret out the truth.
A chancellor told me recently of a case he had in which he overruled the father’s petition to modify custody. It was unquestionably a case in which the father was unfit, and the mother’s situation was better for the child. It was not a close case. Seven months later, however, the mother’s live-in, convicted-felon-boyfriend shot and killed the four-year-old son because he wet the bed. No one hid the information that the mother had someone like that living with her from the judge; it was a situation that developed after the case was concluded. Had it been part of the facts existing at the time of the modification, the judge could have taken other measures to protect the child, but only if someone made it known.
In my opinion, in cases involving the best interest of a child, you have a higher duty.
A Publication Hiccup
February 3, 2015 § 2 Comments
Last week the Meridian Star newspaper failed to publish legal notices scheduled for Tuesday, apparently by oversight. The paper called the lawyers who had had items scheduled and offered to republish any way the lawyers directed.
This caused some heart palpitations that influenced two lawyers to seek out my position on the matter, since estates assigned to me were affected. Each were running second and third publications. They had directed the paper to publish on three consecutive Tuesdays, and were concerned about the variation in days.
Before getting to a response, let’s look at the two most commonly invoked provisions on point:
- MCA 91-7-145(2) states that notice to creditors in an estate, conservatorship, or guardianship ” … shall be published for three consecutive weeks.” The requirement clearly is that the publication be made once in each of three consecutive weeks. The day is immaterial.
- MRCP 4((a)(4)(b) for process by publication is even clearer. It specifically provides that ” … publication of said summons shall be made once in each week during three consecutive weeks …” Again, the specific day of the week is immaterial.
So the answer, simply, is that so long as the paper publishes your notice or process one time in each of three consecutive weeks, regardless of the days when the notices are published, you have met the requirement of the statute and the rule.
There are other notice statutes. When you must comply with one, follow the express language of the statute.
Sometimes we get caught up in old habits, like telling the clerk at the paper to “Run this the next three Wednesdays …” and that’s how we always do it because that’s how we’ve always done it. But it’s the specific language of the statute or rule that controls, not force of habit.
Trifling with Visitation is no Trifling Matter
February 2, 2015 § Leave a comment
Some of the most bothersome and galling matters with which family lawyers have to contend are problems with visitation. They can include outright denial of visitation, conflicts during exchanges, interference during visitation, refusal to return a child, and every other atrocity one can conjure up. Those calls on the weekend and in the evenings can wear one to a frazzle.
In the case of Ash v. Ash, 622 So.2d 1264 (Miss. 1993), the MSSC affirmed a chancellor’s modification of custody based on a mother’s obstinate refusal to allow visitation and non-compliance with court orders, which the court described as involving the attention of “two prior chancellors and six attorneys” in more than ten court proceedings before the modification judgment.
In the case of Strait v. Lorenz, handed down January 6, 2015, the COA affirmed a chancellor’s decision to modify custody based on Travis Strait’s long-standing denial of visitation to his ex-wife, Kristy Lorenz. The parties had agreed in their irreconcilable differences divorce that they would share joint legal custody of their daughter, Jane, and that Travis would have “primary physical custody.”
Following the divorce, Kristy filed five times for modification and/or contempt, alleging denial of and interference with visitation in most of the actions. Travis filed actions in California and Hawaii for TRO’s, both of which were vacated. The chancellor in Mississippi denied Travis’s efforts to dismiss for lack of jurisdiction or to remove the case from Mississippi based on forum non conveniens.
In her pleadings, Kristy charged that Travis had sexually abused Jane, so the chancellor appointed a GAL to investigate. The GAL’s report was unfavorable to Travis, and, on Kristy’s motion, the chancellor entered an emergency temporary order changing custody to Kristy until the final hearing.
The chancellor awarded Kristy custody and other relief, and Travis appealed.
On the issue of material change, Judge Griffis of the COA said this:
¶27. In Ash, the chancellor issued various visitation-related restraining orders, emergency orders, and modification orders over the course of five years. Id. at 1265. The non-custodial parent then filed another motion to change custody and find the custodial parent in contempt. Id. The chancellor granted the motion, finding a material change in circumstances had occurred. Id. In affirming the chancellor’s ruling, the supreme court found that the visitation dispute was tackled by “two prior chancellors and six attorneys, [and] more than ten court proceedings,” none of which resolved the issue. Id. at 1266.
¶28. The facts in this action are comparable to Ash. As in Ash, the chancellor here contemplated liberal visitation, which was deliberately denied. See id. Also, there was an “onslaught of pleadings . . . stemming from visitation problems,” none of which were resolved by the chancellor’s orders. Id. at 1265.
¶29. Travis admittedly ignored Kristy’s attempts to contact him and would not allow Jane to take Kristy’s phone calls. The chancellor encouraged communication between Kristy and Jane through email and mail, but Travis disabled Jane’s email account that Kristy had created for her and there was testimony that Jane did not receive cards mailed to her. We cannot find the chancellor erred in finding the repeated failure to comply with visitation order was a material change in circumstances, for which contempt orders would not resolve.
¶30. Travis argues that the lack of visitation was not a “change in circumstances,” but rather a foreseeable, continued animosity between the parties that existed from the time of divorce. We cannot find that the chancellor anticipated, at the time of the divorce decree, that Travis would continuously refuse to comply with the visitation orders. Also, we note that no a single act of denying visitation amounted to a material change in circumstances. Rather, as in Ellis [v. Ellis, 952 So.2d 982 (Miss App 2006)], it was the “continued violation of court orders pertaining to visitation and continued hindering of the visitation time” that amounted to a material change in circumstances. Ellis, 952 So. 2d at 990 (¶17) (emphasis in original). Given the severity of the denial of visitation, we cannot find the chancellor abused his discretion in finding the denial of visitation was a material change in circumstances.
So the key is the “severity of the denial of visitation” which, from the cases, must be long-standing and extreme, and most likely involve repeated violations of court orders.
You should note that the proof in Strait included testimony of a mental health professional that the father’s conduct did have an adverse effect on the child. The opinion did not say so, but it apparently is not enough merely to show alienation and interference with contact; rather, the proof must show that the alienating behavior did have an adverse effect on the child, and the testimony of a mental health professional is probably the best means of doing that. In Strait, Travis’s behavior was so adverse that the chancellor characterized his custodial environment as “poisonous.”
I agree that most visitation disputes are more vexing than dangerous, and more paltry than extreme. Yet, if more parents understood that interference with visitation could lead to modification of custody, I believe it would result in far fewer visitation disputes in court.
The Courthouses of Mississippi
January 30, 2015 § 8 Comments
Starting next month, I’m going to be posting photos of the courthouses of Mississippi.
The twist is that I am asking you to send me your photos to be published here. Here are the guidelines:
- The pic must have been taken by the submitter. Cell-phone pics are welcome.
- Sunshine shots only; no low-contrast, cloudy days.
- Please avoid power, cable, and telephone lines in your photos. Your favorite people or clients are fair game, though, if they are okay with it.
- You will be credited by name, unless, for some reason you’d rather not.
- I’ll post as many as 4-6 a month, provided I have them.
You can email them to me at lprimeaux@comcast.net.
By my reckoning, there are some 91 or 92 courthouses in Mississippi, and several more when you count separate chancery buildings, so this could take some time unless you send me your pics asap. I’m relying on you to provide me with the full compliment. Next time you head to a courthouse, take a minute to send me a photo.
If this goes well, we may try the courtrooms of Mississippi next.
Reprise: Equitable does not Mean Equal
January 29, 2015 § Leave a comment
Reprise replays posts from the past that you might find useful today.
EQUITABLE DIVISION AND MARITAL FAULT
August 24, 2011 § 4 Comments
It is almost a platitude of Mississippi law that, “Courts may divide marital assets between divorcing spouses in a fair and equitable manner — equal division is not required.” Bell, Mississippi Family Law, § 6.01[4].
The sticking point is where to draw the line between “fair and equitable” and “equal.” The appellate decisions come in all sizes, colors and flavors.
Bond v. Bond, decided by the COA August 16, 2011, is the latest iteration on the point. In that case, Jimmie Lee proved that his wife, Donna, had committed adultery during their four-year marriage. The chancellor awarded Jimmie Lee 90% of the equitable division, and gave Donna the remaining 10%. Jimmie Lee appealed, aggrieved that Donna got such a generous share, and charged that the chancellor erred in failing to make sufficient findings of Donna’s adultery.
Judge Maxwell’s opinion sets out the applicable law about as clearly as can be done:
In ordering an equitable distribution of property, chancellors must apply the Ferguson factors, which include:
(1) contribution to the accumulation of property, (2) dissipation of assets, (3) the market or emotional value of assets subject to distribution, (4) the value of assets not subject to distribution, (5) the tax and economic consequences of the distribution, (6) the extent to which property division may eliminate the need for alimony, (7) the financial security needs of the parties, and (8) any other factor that in equity should be considered.
Hults v. Hults, 11 So. 3d 1273, 1281 (¶36) (Miss. Ct. App. 2009) (citing Ferguson v. Ferguson, 639 So. 2d 921, 928-29 (Miss. 1994)). Chancellors should also consider each party’s marital fault. Singley v. Singley, 846 So. 2d 1004, 1013-14 (¶26) (Miss. 2002). There is a presumption that “the contributions and efforts of the marital partners, whether economic, domestic or otherwise are of equal value.” Hemsley v. Hemsley, 639 So. 2d 909, 915 (Miss. 1994). In reviewing a chancellor’s findings, we do not conduct a Ferguson analysis anew. Goellner v. Goellner, 11 So. 3d 1251, 1264 (¶45) (Miss. Ct. App. 2009). Rather, we examine the chancellor’s judgment and the record to ensure the chancellor applied the correct legal standard and did not commit an abuse of discretion. Id. at 1266 (¶52).
In Carrow v. Carrow, 642 So. 2d 901, 905 (Miss. 1994), the Mississippi Supreme Court held that a chancellor erred in finding a wife’s “adulterous conduct precluded her from being entitled to any form of equitable distribution of the property upon divorce.” The Carrow court instructed that chancellors should not view equitable distribution as a means to punish the offending spouse for marital misconduct. See id. at 904 (citing Chamblee v. Chamblee, 637 So. 2d 850, 863 (Miss. 1994)). Rather, “marital misconduct is a viable factor entitled to be given weight by the chancellor when the misconduct places a burden on the stability and harmony of the marital and family relationship.” Id. at 904-05 (citing Ferguson, 639 So. 2d at 927).
The court found that the chancellor had, indeed, taken into consideration Donna’s fault when he considered the Ferguson factor dealing with the parties’ relative contributions to the stability and harmony of the marriage. The chancellor had found under that factor that:
“Neither Jimmie nor Donna did all they could to provide stability and harmony to the family. Donna became infatuated with another man and her romantic relationship with this third party caused the dissolution of the marriage.”
So here are a few points to ponder about this decision:
- The rule that equitable division does not require an equal division, but only a fair division, is alive and well.
- A 90-10 split in equitable distribution will be found fair if the judge addresses all of the Ferguson factors and justifies the decision.
- The judge is only required to address all of the Ferguson factors, not to analyze them in excruciating, lengthy detail. In this case, the chancellor’s two-sentence recitation was found adequate to support the award.
This case reminded me of the student who got a 90 on a test and wanted the teacher to re-grade it in hopes of an even better grade. Jimmie Lee’s “grade” stayed the same after the appeal, but it’s somewhat of a head-scratcher why he appealed in the first place, given the pretty clear holding in the Carrow case.
When is a Constructive Trust Appropriate?
January 28, 2015 § 1 Comment
Jeanette Brown and Edward Wilson (Brown) filed suit against Virginia Jones and others (Jones) to set aside a will and some inter vivos gifts made in favor of Jones by the decedent, J.T. Smith. After a trial, the chancellor upheld the will, but did order that the $484,000 in inter vivos gifts were the result of undue influence, and ordered that they be repaid to the estate.
Brown appealed, claiming inter alia that the trial court erred by not imposing a constructive trust on the funds.
The COA, In the Matter of the Last Will and Testament of J.T. Smith: Brown, et al. v. Jones, et al., handed down September 2, 2014, affirmed the chancellor’s decision not to impose a constructive trust. Judge James, for the court:
¶39. A constructive trust has been defined as follows:
A constructive trust is one that arises by operation of law against one who, by fraud, actual or constructive, by duress or abuse of confidence, by commission of wrong, or by any form of unconscionable conduct, artifice, concealment, or questionable means, or who in any way against equity and good conscience, either has obtained or holds the legal right to property which he ought not, in equity and good conscience, hold and enjoy.
Yarbrough v. Patrick, 65 So. 3d 865, 871 (¶28) (Miss. Ct. App. 2011) (quoting Alvarez v. Coleman, 642 So. 2d 361, 367 (Miss. 1994)). A constructive trust is “a means by which one who unfairly holds a property interest may be compelled to convey that interest to another to whom it justly belongs.” Van Cleave v. Estate of Fairchild, 950 So. 2d 1047, 1054 (¶29) (Miss. Ct. App. 2007). A constructive trust “arises by implication from the relationship and conduct of the parties and may be established by parol testimony.” Id. “It is the relationship plus the abuse of confidence that authorizes a court of equity to construct a trust for the benefit of the party whose confidence has been abused.” Id. at 1054-55 (¶29). Finally, “the proponent of such a trust must show its necessity by clear and convincing evidence.” Yarbrough, 65 So. 3d at 871 (¶28).
¶40. Here, we find that Brown has failed to show, by clear and convincing evidence, that a constructive trust is necessary. The chancellor found that a confidential relationship existed between Jones and Smith and that Jones failed to rebut the presumption of undue influence, which arose due to that confidential relationship. However, the chancellor did not find that Jones abused the confidential relationship, only that she failed to rebut the presumption of undue influence that arose by operation of law due to the existence of a confidential relationship. Absent a finding of fraud, duress, abuse of confidence, commission of wrong, unconscionable conduct, or the use of other questionable means, we are not compelled to impose a constructive trust.
¶41. Furthermore, a constructive trust is typically imposed where the aggrieved party has no adequate remedy other than through equity. As our supreme court has stated, “[a] constructive trust is raised by equity to satisfy the demands of justice.” Church of God Pentecostal Inc. v. Freewill Pentecostal Church of God Inc., 716 So. 2d 200, 207 (¶23) (Miss. 1998). The supreme court has further noted:
A constructive trust is a fiction of equity. It is the formula through which the conscience of equity finds expression. When property has been acquired in such circumstances that the holder of the legal title may not in good conscience retain the beneficial interest, equity converts him into a trustee. The equity must shape the relief and courts are bound by no unyielding formula. Id. (quoting Russell v. Douglas, 243 Miss. 497, 505-06, 138 So. 2d 730, 734 (1962)).
¶42. However, here, we fail to see why the remedy ordered by the chancellor was inadequate, necessitating the imposition of a constructive trust. The chancellor ordered that the $450,000, which was removed from Smith’s AmSouth account and placed in the various CDs, and any interest earned upon the funds, be returned to the estate and distributed pursuant to the terms of the will.
¶43. We find that the chancellor did not abuse his discretion by failing to impose a constructive trust and Brown has failed to demonstrate, by clear and convincing evidence, that a constructive trust is necessary here. Accordingly, this issue is without merit.
The key point here is that you must establish by clear and convincing evidence that a constructive trust is necessary, and that other avenues of relief would be inadequate. It’s within the chancellor’s discretion. In this case, the chancellor was satisfied, apparently, that the funds were readily identifiable, available, liquid, and would be repaid — all without the necessity of a constructive trust.
The Importance of a Hold-Harmless Clause
January 27, 2015 § 1 Comment
Jeremy and Tiffiny Moseley entered into a property settlement agreement (PSA) that was incorporated into their 2000 irreconcilable differences divorce judgment. One of its terms was that Jeremy would have “exclusive use and possession of the 1998 Chevrolet Camaro,” and that he would be “solely responsible for the payment of all debt, insurance, and taxes associated with said vehicle. The agreement also provided that Jeremy would “hold [Tiffiny] harmless for any debt associated with said vehicle.”
Following the divorce, Jeremy filed for bankruptcy in Arizona, where he had moved. He listed as a creditor the lienholder on the Camaro, Trustmark, but he did not list Tiffiny as a co-debtor or separate creditor based on the hold-harmless language. Jeremy was discharged in bankruptcy in 2001. [Note that this was a pre-2005-amendment non-support obligation that was dischargeable in bankruptcy]
Trustmark sued Tiffiny and obtained a judgment against her for more than $15,000, plus interest.
Tiffiny sued Jeremy for contempt for non-compliance with the hold-harmless clause. The chancellor held that the bankruptcy had no effect on his obligation to Tiffiny under the hold-harmless clause, and awarded her a judgment against him, plus interest and attorney’s fees. He appealed.
In Moseley v. Smith, decided December 2, 2014, the COA affirmed, and Judge Maxwell’s opinion includes some significant language about hold-harmless clauses that you need to file away for future use:
¶16. We begin with the bankruptcy issue. Moseley seems to treat his financial obligations involving the Camaro as a singular debt—a debt he owed to Trustmark, which was discharged in his Chapter 7 bankruptcy. But Moseley actually had two debts connected to the Camaro—(1) the debt to Trustmark bank to repay the car loan, and (2) the contingent debt to Smith, which would arise if Trustmark went after her for repayment of the car loan. While Moseley listed the first debt to Trustmark on his bankruptcy petition, he omitted his second debt to Smith. He also failed to otherwise notify Smith that her rights as a creditor may be affected by his bankruptcy petition. Thus, his debt to Smith was not covered by his bankruptcy discharge. See In re Hill, 251 B.R. 816, 821 (Bankr. N.D. Miss. 2000) …
¶17. In bankruptcy terms, the provision in the property-settlement agreement that Moseley would hold Smith harmless for any debt associated with the Camaro “create[d] a ‘new’ debt, running solely between the former spouses.” In re Jaeger-Jacobs, 490 B.R. 352, 357 (Bankr. E.D. Wis. 2013) (citing In re Schweitzer, 370 B.R. 145, 150 (Bankr. S.D. Ohio 2007)). Under the version of the United States Bankruptcy Code in effect during Moseley’s 2001 bankruptcy, this type of debt was presumptively non-dischargeable as a non-alimony debt “incurred by the debtor in the course of a divorce or separation or in connection with a separation agreement, divorce decree or other order of a court of record[.]” In re Clark, 207 B.R. 651, 655 (Bankr. E.D. Mo. 1997) (quoting 11 U.S.C. § 523(a)(15) (1994)).
The opinion goes on to analyze the notice requirements in effect at the time of Jeremy’s bankruptcy, and how failure to give Tiffiny notice affected her ability to file a timely objection. Those notice and objection requirements were changed by the 2005 amendments to the bankruptcy laws.
The important point here is that when you add hold-harmless language to your PSA you are creating a new debt between the parties that is most likely not dischargeable, is entirely separate and apart from the underlying obligation, and is enforceable via contempt in chancery court.
It would seem to me that even without the hold-harmless language the agreement between the parties is a separate contractual obligation that would be entirely enforceable; however, the authority cited by Judge Maxwell raises the point to a higher level and should remove all doubt if the hold-harmless language is included.
It’s simple to add that hold-harmless language to your PSA templates. It won’t hurt your client if she is the co-debtor who will not be paying the debt, and it just might make a crucial difference somewhere down the line — and that, after all, is your job.
Judicial Redistricting: An Invitation to Comment
January 26, 2015 § 6 Comments
Judicial redistricting is upon us. The legislature is studying judicial redistricting, which, as I understand it, must be enacted in this session.
My question to you citizen-lawyers is: How would you redistrict our courts?
Send me a comment about how you’d do it. You can go macro, commenting on the whole ball of wax, so to speak. Or you can comment on a particular county or district. I’d like for you to include your rationale.
COA Judge Ken Griffis offered his take on what the legislature might have in mine in this post on his blog.
How would you redistrict our courts? Have at it.
Scene in Mississippi
January 23, 2015 § 8 Comments
