North Oakland Divorce Blog

Care Required in Drafting Prenuptial Agreements

2011-06-11T09:35:00.000-07:00

What happens if there is unclear language in a prenuptial agreement, will it be enforced by the court?

An example is the case of the Estate of Timmer. In the case the court was asked to decide how the language in the prenuptial agreement applied to a condo after both had passed away.

Each party was previously married and had children from their previous marriage. They also had assets from their previous lives and marriages. The prenuptial stated contained a paragraph that indicated that they could purchase jointly held property. The jointly held property would basically pass to the other spouse by operation of the law and be exempted from the prenuptial agreement. There was an additional sentence which specifically stated that they intended to purchase a condo (the condo at issue). The condo would be held jointly by the parties and included language that it would pass to the other party upon death of either, but, it went on to say that the surviving spouse would retain a life estate in the property after the death of the first spouse to pass away.

The life estate would allow the surviving spouse to continue living in the condominium until he or she passed away and then it would be divided between the couple’s two estates. The prenuptial agreement did not state this intent specifically, rather it used conflicting legal terms which were inaccurate.

The problem is that it would not be necessary to reserve a life estate to the surviving spouse if the property was, to pass to the other party upon the death of the first spouse, because the entire property would be owned by the surviving spouse. This created an ambiguity in the prenuptial agreement.
The wife passed away first and the husband transferred the condominium to a trust for the benefit of his heirs. When he passed away the children of the wife requested a fifty percent interest in the condominium from the husband’s heirs, which they refused to grant. The two estates then sued each other in probate court.

The trial court should have considered evidence of the parties’ intent in drafting this agreement. This means that the Michigan Court of Appeals found that this ambiguity would allow the two competing estates to provide evidence from experts and other witnesses as to what they intended to do with this condominium, even though they couple signed this prenuptial agreement which they must have expected to deal with this issue.

The drafting lawyer should have used more specific language regarding how the parties intended to handle this property. The drafter, the husband's brother also used the wrong words when referring to the manner in which the property was to be held.

This ambiguity defeated the reason for the prenuptial agreement in the first place. The court may have decided that the intent was different then what the parties had really intended. Care must be taken to specifically explain the intent of the parties and use proper language that does not conflict and one should not use a relative to draft their legal documents.

Served with Divorce Papers, Now What?

2011-05-19T12:17:00.000-07:00

The Issue

Last week I answered the telephone and a gentleman from Troy, Michigan asked me, I have been served with divorce papers, now what?

The Answer

First, you must look at the papers that your spouse has filed. There should be a complaint for divorce and a summons at the least. You should also look to see whether there are ex-parte orders and whether your case is scheduled as an e-filing case.

If there is only a summons and complaint, you have twenty-one days from the date that you were served to file an answer to the complaint. The answer should be captioned in the same way as the complaint and you should provide an answer to each numbered paragraph in the complaint. For instance, you should admit or deny the allegations such as admitting or denying that you have lived in the State of Michigan for at least 180 days prior to the date of filing. The answer must be filed with the court and served upon your spouse’s attorney within twenty-one days after you were served.

If you fail to file an answer your spouse can seek to enter a default against you. If a default is entered against you, you will have very little if any input in how the case proceeds. Your spouse can then, after the appropriate waiting period, attempt to enter a default judgment of divorce with very little input from you. If the judge believes that the proposed default judgment is “equitable” then the judge will sign the judgment and that will be that. It is very important that you file an answer within the twenty-one day period.

In addition, when you file the answer to the complaint for divorce, you should file any counterclaim for divorce at that time. If you do not file it when you file the answer to the complaint for divorce, you will not be able to file a counterclaim.

If you have been served with ex-parte orders as well, then you have fourteen days to file an objection to the ex-parte orders. An ex-parte order is an order that the court will grant at the beginning of the case without the presence of the other party and without a motion. If you fail to file an objection and schedule a hearing then the ex-parte order will be a standing order that will be in force until further order by the court or the end of the case. Two frequently granted ex-parte orders are an order to maintain the status quo and a restraining order against transfer of property. A status quo order will require the parties to continue to pay the bills during the divorce as they did during the marriage and a restraining order will stop either party from withdrawing funds other than for everyday use.

If your case is an e-filing case, then you must follow the rules indicated on the forms provided to you to file your documents online. If you try to simply file the documents by mailing them to the court or filing them at the court, this will not work. You have to use the e-filing system in order to preserve your rights.

The best thing to do is to find a divorce or family law attorney as soon as possible and meet with them. You can speak with your accountant, friends or family to help you locate an attorney. You should look to meet with an attorney that limits their practice to family law as many attorneys will handle divorce matters, but that is not their primary area of practice. Even if you believe that you have a simple matter, it is always advisable to have a lawyer help you with this process. There are many pitfalls in this area and you do not want to make things worse than they have to be when you are already facing a difficult situation.

No Credit for Negative Equity

2011-04-16T12:03:00.000-07:00

The Issue
The married parties own a home or other real estate that has an appraised value that is lower than the amount of secured debt owed on the home. This is often referred to as being "upside down" on your home. If one spouse keeps the property in the divorce, can they request a credit against other savings or assets for their assumption of this negative equity?

The Apparent Answer
There is no currently published (or unpublished) court of appeals or supreme court decisions in Michigan directly addressing this relatively new phenomenon. It appears that the circuit court judges are not willing to grant the party that assumes this potential liability a credit against other assets. There are several potential reasons behind these decisions.

The parties are both still liable on the note or underlying debt. Even if there is a hold-harmless or indemnification clause, if the party that takes the house then walks away and stops paying, the note holder (bank) can still sue both parties on the debt. The divorce judgment cannot force the bank to remove one of the parties from the liability associated with the same and if the parties owe more money on the home than it is worth, in most cases the bank won't agree to remove one name or allow refinancing. So the party that does not keep the house may still be sued on the liability despite the divorce judgment and the hold harmless clause may be useless if the spouse that kept the house is "uncollectable". Finally, if this situation occurs and the spouse that kept the house was given additional property to credit them for this liability, then the other spouse is facing a double loss, the loss of the property and getting sued for the deficiency by the bank.
The court believes that there is greater value to the party that keeps the house than the appraised value. The court looks at the holder's value of the property rather than the appraised value. The court thinks that if the person is willing to keep the house despite this apparent negative equity that it must be worth more to that person than the general home buying public, perhaps due to the children's school, some amenities in the house or the party really just doesn't want to move.
The court may look at the house like the stock market, the value is down now but it will go up. If one party wants to keep the house, then they must bear the risk of loss as well as the potential benefit of gain.

There are likely other reasons that the courts have not wanted to grant a credit for the negative equity, but these are some potential reasons.

Solutions to the Negative Equity Issue

The parties can sell the house and come to the table with money from joint funds for the deficiency between the proceeds from the sale and the overall debt.
One party can keep the house and then agree to sell it in a set number of years to wait and see if the market goes up and then divide either the debt or the gain. The parties must then decide what will happen if the spouse responsible for paying the debt defaults and how to handle the payment of taxes and the deductions for payment of the mortgage.
The parties could short sell the home. In a short sale, one of the parties will have to include the difference between the sale price and the debt as income on their tax returns. The parties must work out a mechanism to share the taxes on this reported income.
Finally, both parties could walk away from the home, allow the foreclosure and both will potentially face the bank filing a complaint against them to collect the deficiency in the future.

These are only some potential ways of dealing with this solution. The parties divorce lawyer must be creative but practical as there are several potential pitfalls in this evolving area of divorce law.

DIVORCE AND COLLAPSE OF THE REAL ESTATE MARKET

2011-04-09T11:24:00.000-07:00

DIVORCE JUDGMENT LANGUAGE
On April 7, 2011, the Michigan Court of Appeals decided a case that dealt with the interplay of the real estate market collapse and judgments of divorce. In the case of Neill /f/k/a Schmoke v Schomke, Docket No. 294878, unpublished, the husband agreed in the consent divorce judgment to a provision where he would pay his wife the amount of $1,074,000 for her share of the value of the marital home upon the sale of the home or after five years from the entry of the judgment. Further, the judgment stated that this sum would become a money judgment after five years.

COLLAPSE OF THE REAL ESATE MARKET
The house did not sell, not only that, the Defendant lost the home in foreclosure before the expiration of the five year period. His former wife then executed upon the money judgment and sought payment of the $1,074,000. The reality of the situation is that the real estate market in Michigan collapsed and most people, regardless of their intelligence, did not foresee the devastating extent of this collapse. The defendant in this case is a doctor and a well-educated and intelligent person whom like most here did not foresee this collapse.

The trial court took this problem into consideration and decided basically that due to the collapse of the real estate market that it would not be fair to force the Defendant to pay this full amount. The flip side of this argument whether it is fair to the ex-wife in this situation where she bargained for and contracted for an exact amount of money for her share of the home.

IMPORTANCE OF THE SPECIFIC LANGAUGE IN THE DIVORCE JUDGMENT
The Michigan Court of Appeals reversed this decision. The court paid a lot of attention to the exact wording of the judgment which stated that the amount due would become a money judgment. The appellate court found that due to this specific language particularly that after five years the amount would become a money judgment, the judgment was not subject to modification except in very limited circumstances.

The appellate court decided that it would be more unfair to the ex-wife to modify the amount of money due to her from the ex-husband as they both made a strategic decision to settle the matter and that he should not be relieved from his bad decision merely because his assessment of the consequences was incorrect. So it would appear that the court held the Defendant to his bad bargain and looked more to contract law in enforcing the judgment than it did to the traditional equitable or fairness arguments that would otherwise control in a divorce matter.

One last note of interest in the decision itself, was that the trial court believed the collapse of the real estate market in Michigan was an extraordinary circumstance that should allow revision of the judgment, the appellate court stated that while the “downturn was unfortunate” it could not be characterized as “entirely unforeseeable or extraordinary”. So despite the fact that it appears the extent of the collapse of the market is historically unique in this part of the country, the court still decided that people should have somehow been prepared for this potential when drafting the judgment of divorce.

COMPARE TO PRENUPTIAL AGREEMENTS
The court treated this judgment the way that the courts appear to be treating prenuptial agreements. The court favors enforcing the contractual provisions without attempting to balance the equities of the situation. Just as the courts have strongly trended toward enforcement of prenuptials as written without attempting to rebalance the equities between the parties, so here the court held the defendant to his bargain without attempting to rebalance the burden between these parties. Ten years ago, it is my belief that the outcome of this case would have been different and that this is an example of the ascendancy of contract law in the area of matrimonial law.

LESSONS LEARNED
There are a number of lessons one may learn from this case. First, every word and phrase in a judgment of divorce must be drafted and reviewed with care. If the use of the term “money judgment” was avoided, there may have been a different outcome in this case. Second, that the term foreseeable is very narrow when viewed in the eyes of the court and applied to divorce judgments. Finally, the court continues to rely more and more upon contractual principles in the area of matrimonial and appears to be moving away from equitability or fairness to both parties. From prenuptials to judgments of divorce, one must be very careful when drafting these agreements as the courts will enforce them as written.

Save Your Marriage, Be Nice to Your Spouse

2011-04-02T11:39:00.000-07:00

I deal with divorcing couples all the time. No-one wants to get divorced, but by the time they get to me, the relationship is typically over. Do not take your marriage or your relationship for granted. Here are some suggested thoughts on trying to make your spouse happy, which in turn should make for a better relationship and hopefully avoid the disastrous consequences that can be a result of a relationship turned bad.

Try taking a weekend trip somewhere that your spouse wants to go or visit. It does not have to be "Dutch Amish Country" but just get out of the house. Maybe even a local hotel with a swimming pool and sauna. Have the grandparents watch the kids or hire a babysitter to watch them overnight.

Take your spouse to an event that they would enjoy. Maybe try the Detroit Opera House for your wife or a Red Wings game for your husband. Go see a movie together and indulge with a big tub of popcorn. Then stay the night out somewhere.

Next time you disagree with your spouse, maybe let them have the final word. You are sometimes better off not saying everything that you think. The instant gratification of telling your spouse that they are an idiot often results in serious negative consequences that are just not worth it. We all act like idiots sometimes, your spouse will figure it out. You don't have to point out all of their errors or shortcomings.

Try to be as supportive as possible. Listen to what they tell you when they are complaining about something. You do not have to offer a solution, you just have to listen and act like you care (because you do of course care about them).

Say something nice to your spouse about them. We all have to deal with difficulties and people that are trying to cause problems for us, when we come home we as spouses should attempt to be there for our partners. A kind word here and there really helps and who doesn't like to hear nice things about themselves.\

Don't worry if you feel that you are the only one that is trying to please the other person. Hopefully they will come around after some persistent niceness and caring on your part. Even if you feel like you are doing all the accommodating of the other person's feelings, it may be worth it. Like my dad says, life is hard but the alternative is worse.

Good luck, be nice.

Amicable Divorce Solutions Avoid Astronomical Attorney Fees

2011-03-12T12:36:00.000-08:00

I practice in the area of family law or divorce in Oakland County, Michigan. My experience leads me to believe that power and control issues are the biggest cause of divorce. There are several reasons to avoid carrying these issues forward into a divorce proceeding.

Huge attorney fees can result from power and control issues in divorce cases.

When a divorcing couple cannot resolve parenting time and custody issues, the result, among other things, is astronomical attorney fees. Unfortunately these important issues often become another opportunity for a power and control struggle between two adults that can't talk to one another. Too often one divorced parent will make a decision regarding the child and take action on that decision without discussing it with the other parent. This appears to be what happened in the case of the Pierron family.

In the post-divorce case, Pierron v. Pierron, decided by the Michigan Supreme Court in 2010, a divorced couple could not come to an agreement on which school their child should attend, which appears to be the result of unresolved power and control issues between this divorced couple.

One should undestand that in Michigan where parents share joint legal custody, they share joint decision making powers regarding important life issues that affect their children. The courts usually grant joint legal custody. Case law indicates hat where a child attends school is one of these issues that the parents must decide together when they share joint legal custody. If they cannot, the courts will decide for them and this is what happened in the Pierron case.

This issue of which school the child should attend in the Pierron case led to a protracted legal battle which led all the way to the Michigan Supreme Court. After the court made its decision, the mother of the child filed a motion to have the father pay for her attorney fees. In Michigan, a court may order one parent to pay for the other parent’s attorney fees in a divorce (or post-divorce case) where the court finds that the parent requesting payment does not have sufficient assets to pay for the attorney fees and the other parent does have sufficient assets.

In this case, the mother apparently incurred a whopping bill of $136,449.12 in attorney fees in a struggle over which school the child should attend. The court ordered the father to pay for $64,599.12 of her attorney fees. This means he had to pay her attorney this money in addition to whatever amount he incurred in his own attorney fees, ouch!

This is a whole lot of money to pay over a dispute about which school their child should attend. It would seem that they both would have saved a lot of time, money and emotional stress if they could have rationally and reasonably discussed this issue and come to a decision between the two of them without the court intervention.

Neither party comes out ahead when the mother still has to pay for close to $72,000 in attorney fees and the father has to pay $64,599.12 of her attorney fees in addition to his own. Further, this was a post-divorce case and does not even address the amount of fees they incurred in the original divorce. This is all money that they could have kept for themselves or spent on their child’s college education if they were so concerned about the child’s education and welfare.

The conclusion is that allowing power and control issues to motivate and control a divorce proceeding is a big mistake. Resolving all matters in a reasonably amicable divorce without egos and emotions is the best way to go, particularly when there are children involved. If one does not, then this can result in repeated court struggles throughout the life of one's children. This is not only damaging to the children but it can result in astronomical attorney fees as well. One must be careful in choosing a divorce lawyer, a family law attorney that does not understand the cost of litigation and the value of an amicable divorce can cause a lifetime of problems.

Reading List for People in all Stages of Divorce

2011-02-08T07:59:00.000-08:00

I have practiced in the area of family law (sometimes considered a euphemism for divorce lawyer) in the Rochester Hills, Michigan area for several years. The following books may be helpful for you to read if you are considering divorce, are in the middle of a divorce, or have just come through a divorce. Probably the most important issues in any divorce is preparation and support. Knowing what to expect from the process of divorce can help alleviate some of the loss and confusion associated with this process.

Contemplating Divorce: A Step-by-Step Guide to Deciding Whether to Stay or Go
by Susan Pease Gadoua

The book includes practical lessons in what needs married couples have and ways to fix problem areas in your relationship. By taking a look at the assumptions and expectations of the relationship with your spouse, you will be in a position to explore the reasons you are thinking about divorce.

Divorce and Money : How to Make the Best Financial Decisions During Divorce
by Violet Woodhouse

This book offers detailed and practical advice on how to look at your finances with a clear mind through this difficult time. Everyone needs to learn the hard facts about their financial future after a divorce.

The Divorce Organizer & Planner
by Brette Sember

This divorce workbook streamlines the process even when enduring a difficult split. You'll find easy to understand planners for everything needed to prepare for the legal, emotional, and financial aspects of your divorce.

Nolo's Essential Guide to Divorce
by Emily Doskow, Attorney

The book is well organized and easy to read, without all the legal language getting in the way, but enough to make the information valuable. If you're looking for no-nonsense divorce information, try this book first.

Helping Your Kids Cope with Divorce the Sandcastles Way
by M. Gary Neuman

This book is based on the group session for children of divorced parents. In this book you'll find exercises designed to increase communication, understanding, and togetherness between parents and kids. You'll find suggestions on how to break the divorce news to a child, how to handle the holidays, visitation, custody arrangements, anger, discipline, co-parenting, single parenting, overcompensation, sorrow, custody fights, and much more.

Standing on My Own Two Feet: A Child's Affirmation of Love in the Midst of Divorce
by Tamara Schmitz

This book focuses on the preschool to first grader. The main points of this book are unconditional love and not being blamed for the divorce. Because of this book's positive attitude and easy-to-understand message, this book is an excellent choice for young children, and their parents.

Dinosaurs Divorce
by Marc Brown

Sometimes kids can express their feelings better through friendly, recognizable characters. Dinosaurs are beloved by most young kids, so when dinosaur-kids are going through difficult divorce situations, young readers can relate.
How to Parent with Your Ex: Working Together for Your Child's Best Interest
by Brette McWhorter Sember

With simple, commonsense advice, this book gives parents, both custodial and non-custodial, the tools they need to raise their children after a divisive divorce. The book encourages both sides of divorce to understand the other’s point of view. By focusing on the child, both parents are able to form a solid relationship with the child and maintain necessary, positive communication with the ex-spouse.

The Co-Parenting Survival Guide: Letting Go of Conflict after a Difficult Divorce
by Elizabeth Thayer Ph.D. & Jeffrey Zimmerman Ph.D.

Divorce is painful for everyone involved. However, when couples harbor resentment and anger toward each other, the children suffer even more. Too often arguments over visitation, holiday plans, and simple day-to-day events can send family's into chaos, pain, frustration, and very often acting-out in the child. This guide can help parents work through their conflict and come together for the children.

Rebuilding: When Your Relationship Ends
by Bruce Fisher

This book is written by a divorce therapist who uses a realistic, but comforting, look at the process of healing after a divorce. This nineteen-step process walks you through the pain of the aftermath of divorce all the way to recovery. Many people say after they go through the process outlined in the book, they come out feeling better than they ever have.

The above are only some of the many books about divorce, separation and depression that you may find helpful. You should be able to find any of these books at your local library in Oakland County, Michigan.

Divorced Parents and Moving Out of Michigan

2011-01-22T12:30:00.000-08:00

Many divorced parents with custody of children are considering moving out of Michigan in order to accept new employment. Many times these parents are required to move out of the state in order to find acceptable employment to support their families. This issue becomes complicated when it involves minor children and the parents share joint legal or physical custody. I recently discussed this issue with a friend whose ex-wife was planning to move from Rochester Hills, Michigan to Ohio.

In cases where the divorced parents share joint legal custody, which is true in almost all cases, any party moving more than 100 miles or out of Michigan, even if less than 100 miles, must obtain court approval before they are allowed to move. This includes the non-custodial parent, so that even if one is not have primary physical custody they must still obtain court approval before they move if they share joint legal custody.

The party that wishes to move, must basically show by a preponderance of the evidence, which in laymen’s terms means, a little more likely than not, that they have met statutory requirements. This issue becomes even more complicated if the parents share joint physical custody of the child or the court decides that there is an established custodial environment with both parents.

If the parents share joint physical custody of a child, then after the court determines that a parent may move by a preponderance of evidence, the court must then make a decision regarding the change of custody. If the court finds that from the view of the children the move would change the custodial environment, then the court must make a decision regarding a change of custody.

The idea of a custodial environment means that even if the parents do not actually share physical custody the following problems regarding a change of custody may apply if over an appreciable period of time the child looks to both parents for love, affection, guidance and other similar types of parental support.

If the court finds that there is an established custodial environment with both parents as described above, the court will revisit the custody issue and the parent that wants to move must prove that it is in the child’s best interests to change custody by a clear and convincing evidence standard, which is significantly more stringent than the preponderance of evidence standard indicated above.

The best interests of the child is really a list of 11 different factors and a catch all phrase of any other factors that the court deems relevant. This may be very difficult for a parent to prove and if the parent does not, then despite the finding that the above factors have been met allowing the move, the court will change custody of the child to the parent that is not moving. This is true even where the child spent more time at the home of the parent that proposes the move so long as the court finds there is an established custodial environment with both parents. This may not seem fair to a parent that is moving because they cannot find employment, however, the focus is on the children, not the parent that is facing the hardship.

None of the above applies if the parents do not share joint legal custody. Unfortunately this means that if one is going through a divorce and there is a good reason to believe that they will have to move for employment or other reasons, it would be prudent to fight for sole legal custody for the parent that is contemplating such a move.

E-mail, Privacy and Divorce in Rochester Hills, Michigan. Tips for Avoiding Confrontation or Being Charged With a Crime

2011-01-05T12:19:00.000-08:00

Reading a spouse’s e-mail and discovering information that might lead to a divorce has been considered a crime in Rochester Hills, Michigan by the Oakland County Prosecutor. An article by L.L. Brasier in the Detroit Free Press, December 28, 2010 reported this issue.

First, to those people that are engaged in some activity or communication of any type (including consulting with a divorce lawyer) of which they do not want their significant others or family members to have knowledge please read the following tips to avoid being discovered by your spouse.

• If you are going to communicate by e-mail, you should make sure to change passwords for the account frequently and not write the password down anywhere that your spouse has access.

• It is not a good idea to post anything negative about your spouse or an affair on Facebook or other social sites for many reasons. One reason is that if you post a comment and then someone that has your spouse as a “friend” in their Facebook account makes a comment about your comment then that will post both to your spouse’s (or ex-spouse’s) Facebook page.

• It is also not a good idea to text someone you do not want your spouse to know that you are contacting, take pictures on your phone of any activity that you do not want your spouse to see or even call someone that you do not want your spouse to know you have contacted. People often leave their mobile communication devices around where their spouse or significant other may have access to it and it is very easy to see what numbers have been called recently and redial any that seem suspicious.

Regarding the case above, I cannot tell you how often in my practice over the last fourteen years that I have heard of one married person reading their spouse’s e-mail, social networking site, mobile phone or even their mail after suspecting that they were having an affair.
In the above case the husband took the issue one step further and provided the letter to father of his wife’s child because the person with whom she was having an affair had reportedly beaten her in front of this child. This passing on of the information to the third party is probably what caused the prosecutor to even consider charging him. If it was merely a case of reading the e-mail and confronting his spouse, then there is really no way that this should have been a charge against him.

As it stands, it still seems somewhat ridiculous for the prosecutor to charge him with a crime, as the two lived together at the time, they both used the laptop computer that he used to obtain access to her email account, and the wife apparently left her passwords for different accounts in an unguarded notebook next to the computer. Further, the prosecutor has apparently charged him under a “hacking statute”, which seems unrelated to domestic relationships.

The temptation when someone has suspicion of extramarital activities to snoop in general or particularly to access the e-mail or Facebook account of their significant others is simply too great, especially where the person knows the password or the password is written down in an accessible spot. Charging this man with a crime really opens a massive can of worms that should be left shut. How many people that have gone through a divorce or are currently going through a divorce where this type of information was used against them are going to be contacting the prosecutor at this point and where does she draw the line?

Finally, if the prosecutor starts prosecuting these types of cases, then there are going to be very many people that are technically breaking the law when they access the e-mail or mobile phone of their spouse, possibly even in inadvertent or relatively innocent cases. For example, your spouse leaves his telephone at home open to his photo album and you look through the album expecting to see some nice pictures of your children, but instead you are confronted of him posing with a woman that you do not know. Does this make you guilty of a crime?

I do not recommend that anyone have an affair, however, it seems foolish to open oneself to this easy exposure by using the mobile telephone for any of the above activities. Think hard before engaging in this type of activity anyway, because the joy one may get from it may be short lasted and the damage that it may cause if discovered can be huge and irreparable. In Rochester Hills Michigan it appears that accessing your spouse’s e-mail or even their mobile phone may not only lead to divorce, but also to criminal charges.

Please visit my website for more information regarding divorce or family law at http://camerongoulding.com/default.aspx

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Changing Child Visitation (Parenting Time Modification) in Michigan Just Became Easier

2010-12-08T13:22:00.000-08:00

Altering child visitation time (technically parenting time modification) just became easier in Michigan. Many judges and friend of the court referees believed that in order for a person to obtain more parenting time with their child or to limit the parenting time of the other party, one had to provide proof equal to that which would be required to change custody. I have long argued that this did not make sense because parenting time and custody are two very different things.

There was really no published Michigan Court of Appeals case or Michigan Supreme Court case that dealt directly with this issue directly. There have been unpublished opinions from the Court of Appeals, however, unless a case is published it is not precedent. What this means is that the trial courts and friend of the court referees do not have to follow what the Court of Appeals has said in a case regarding any given issue unless it is a published case. The Michigan Court of Appeals issued a new published decision on December 3, 2010, Shade v Wright, Mich. App Docket No. 296318 (2010)which held that it should be, and now is due to this case, easier to change the parenting time schedule than it is to alter custody.

This case stated that in order to decrease or increase child visitation with a parent there is a more relaxed burden of proof regarding a change of circumstances or proper cause as a threshold issue than there is with custody. The court went further and stated that normal life changes such as those described above are properly considered when deciding this issue.

In the Wright v Shade case cited above, the change that allowed the mother to change the child’s visitation with the father was that their daughter had started high school and her schedule of activities changed. This is exactly the type of change that trial courts specifically can not consider in order to change custody. Many trial courts and friend of the court referees also believed, before this opinion, that this was exactly the type of change of circumstances that they could not consider in order to allow a change to either increase or limit child visitation. Those courts and referees that believed this were wrong and hopefully they will now follow this case when considering these issues because Wright v Shade is binding precedent.

Children do grow older and as they grow older their relationship with each parent will most likely change as they hopefully grow more independent. As much as it may pain a parent, their own child visitation may have to change to allow the child to find his or her own path which may have the child spend more or less time with either parent despite what the court has previously decided or the parent’s previously agreed. One must also consider that as children grow, they are involved in different activities. As their developmental needs change, both parents must be flexible with their parenting time schedule as much as it may pain the parent.

Cameron C. Goulding; Byers & Goulding, PLC

http://www.northoaklandmichigandivorcelawyer.com/

What are Post Nuptial (Postnuptial) Agreements and are they valid

2010-11-19T10:30:00.000-08:00

A post nuptial agreement is basically a prenuptial agreement that a husband and wife prepare and sign after they are married. In my practice, located in Rochester (Auburn Hills), Oakland County, Michigan, I refer to these documents as “midnuptial agreements” because the couple is really signing these agreements during the middle of their marriage when they are not (at least openly) considering imminent divorce or separation. If the couple is contemplating divorce or separation in the immediate future, then that is referred to as a “separation agreement” or “property settlement agreement” and it is advisable to first file a complaint for legal separation (separate maintenance) or divorce before signing such a contract otherwise it may not be valid as discussed below.

It is my opinion that a properly drafted postnuptial agreement is valid in Michigan and will be upheld by the courts. In a 2008 Michigan Court of Appeals case, Wright v Wright, 279 Mich App 291 (2008), the author of the opinion, Judge O’Connell, stated that such agreements were against public policy. However, at the 9th Annual Family Law Institute Seminar on November 12, 2010, Judge O’Connell stated verbally and in his written materials that this was an “oops” and that he was wrong in stating this in such a manner.

In my opinion what this means is that the agreement in the Wright case was not valid because it encouraged the husband to divorce his wife, was written in contemplation of divorce and that the particular agreement in that case was against public policy, not all post nuptial agreements. I have in fact written “midnuptial” agreements which the parties agreed to follow when they divorced which avoided the requirement of litigation.

The basic requirements for post nuptial agreements are the same as prenuptial agreements however there are at least two additional issues one must address. Those two additional issues are:

consideration or what is given or bargained for to support the contract and make it legally binding and
the agreement must not be made in contemplation of divorce, (whereas a prenup must be made in contemplation of marriage).

For any contract to be valid and legally binding, there must be consideration, in the example of an employment contract, one party agrees to work for the other and the other party agrees to pay the worker for that work, this is called consideration. In a prenuptial the consideration is the exchanged promise to marry, each person is promising to marry the other and this exchange of promises is the consideration to support the contract. In the post nuptial agreement, the person that prepares the contract must state in the document the consideration that will support it and make it legally binding.

The promises exchanged cannot be for one party not to file divorce, leave the marital home or stay in the marriage. The family law attorney drafting the agreement should write the agreement very carefully and indicate that the intent of the parties is to enter into an amicable settlement of property issues and not to contemplate or facilitate divorce or separation. If a jduge believes that the intent of the contract was to facilitate imminent divorce or separation that is against public policy in Michigan and the written agreement will not be upheld by the court. This does not mean that the agreement cannot discuss divorce or separation, again however, the divorce lawyer writing or drafting the agreement must be very careful to avoid the appearance that the agreement would encourage one of the people to file for divorce or facilitate the couple’s separation.

A postnuptial agreement will be reviewed by the court under a fair and equitable standard which is a legal term of art and involves procedure as discussed below and it should not be taken literally. While a separation agreement or property settlement agreement are reviewed under general contract principles which means in most cases that even if it is not fair at all to one party, it is still binding so long as procedural requirements are met.

the other requirements (which are the same for both prenuptials and post nuptials) for a valid and binding “midnuptial” (or prenup) are:
the agreement cannot be obtained through fraud, duress or mistake,
the agreement cannot be unconscionable/unfair when signed,
the facts and circumstances cannot have changed so much in an unforeseeable way since the date it was signed that it would be unfair and unreasonable to enforce it,
both parties must enter into the agreement voluntarily and
both parties must disclose all assets and facts before signing the agreement.

The above factors include terms which are legal terms of art and include procedure and legal definitions so they do not necessarily mean what they would in the common usage of our language, particularly with regard to “fairness” and “foreseeable”. The above five factors are complicated and are a separate topic in among themselves.

If the family law attorney or divorce lawyer carefully drafts the postnuptial contract then it should be enforceable in Michigan and can be a valid substitute for a prenuptial contract if you did not get one before the marriage.

DISCLAIMER: This information is provided for general educational purposes only including answers posted to questions at Ask Cameron. It is not intended to be relied on as legal advice. This information may not have been updated to reflect subsequent changes in the law, if any. Your particular facts and circumstances, and any changes in the law, must be considered to determine appropriate legal advice. Always consult with a competent attorney, licensed in your state, to discuss your particular situation. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship between you and Byers & Goulding, PLC and/or Cameron C. Goulding. Please do not send information to us that you consider confidential without first obtaining:
1. A written statement from us that we represent you (a "retention letter") and
2. Permission from Byers & Goulding, PLC or Cameron C. Goulding to provide
Confidential information to us relating to a particular matter.
This information is not guaranteed to be correct, complete or up-to-date. It should not be relied upon or construed as legal advice. You should not act or elect not to act based upon this information without seeking professional counsel. Byers & Goulding, PLC has its office located in Auburn Hills, Michigan. We do not wish to represent anyone in any state in which this information may not comply with all applicable laws and ethical rules, or to represent anyone with respect to legal matters related to the laws of any state or country in which our lawyers are not admitted to practice law.

Cheating Husbands and Wives in Oakland County Michigan Divorces

2010-10-14T13:05:00.001-07:00

If my husband or wife has “cheated” on me, or has otherwise been unfaithful, will it make a difference in my divorce is a question that many people have when they find out about an affair. The answer, in Oakland County Michigan Family Law Courts or Divorce Courts, is yes and no.

I recently have answered many questions that start with “my wife (or husband) met someone on FaceBook and …” In Michigan, we have no fault divorce, so one does not need to state a reason to get a divorce. The real question seems to be whether one will have an advantage for property settlement, alimony (spousal support) or child custody.

Regarding child custody, it does not seem to make a difference whether one party has been unfaithful during the marriage, unless the new partner has some criminal history or is otherwise dangerous to the children. This is true even though moral fitness of the parents is a factor that the courts must take into account when determining custody.

Regarding property settlement, the court may take into account whether one party has been adulterous. However, most judges do not really want to hear these type of details and the party accusing the other of having an affair, must be very careful not to overemphasis this in court. The judges often take a “chicken or the egg” type approach and assume that both parties have wronged one another at some point during the marriage and that there are many reasons the parties are getting divorce.

Regarding alimony (spousal support), the court may take into account whether one party has had an affair during the marriage. Again, as with property settlement, one must be careful not to get caught up in attempting to punish the other party for this during the divorce. It is one factor that taken together with other factors may make a significant difference, such as the length of the marriage, the parties’ relative incomes and the egregiousness or repetition of the activity. However, judges will generally not attempt to punish one party for this type of activity.

In addition, Judges are very skeptical (as should be most people) of anyone that tries to paint themselves as a complete victim and one’s attorney must be very careful when presenting evidence to avoid this perception. The answer to whether a cheating husband or wife will allow one to get a better settlement then is technically yes, but in reality there are many other factors that courts in Oakland County Michigan consider far more important in a divorce case.

North Oakland Divorce Blog: Abandonment & Divorce – Legally Speaking

2010-09-17T13:57:00.000-07:00

North Oakland Divorce Blog: Abandonment & Divorce – Legally Speaking

Abandonment & Divorce – Legally Speaking

2010-09-17T12:53:00.000-07:00

I have been a divorce lawyer in Oakland County Michigan for many years and over the years I have often been asked at the initial meeting “Will I face abandonment issues in my divorce because I moved out of the home or if I move out of the home?”

Fortunately, unlike many issues in divorce, there is a simple answer to this Question. No, you will not. This is true in Michigan and it should be true in any “No-fault” divorce state if you do not live in Michigan.

The explanation is a little more complicated and involves a little history in Michigan Family or Divorce Law. Until the 1970’s, Michigan law required a person that had to get divorced to state a specific reason for the divorce, such as abuse or abandonment on the record. If the person did not state a sufficient reason, the judge could deny the person a divorce. This caused unnecessary embarrassment, humiliation and other more serious issues to innocent people that needed to get divorced.

Abandonment or desertion, as it was technically called in Michigan, was repealed as a basis for divorce when Michigan instated the “No-Fault” rules for Divorce. The statute repealing Abandonment or Desertion as a grounds for divorce in Michigan is MCL §552.9d. (You may review this statute at http://legislature.mi.gov/doc.aspx?mcl-552-9d.)

Michigan no longer requires a person to state specific grounds for divorce. Typically a person recites the phrase “there has been a breakdown of the marital relationship to the extent that the bonds of matrimony have been destroyed” and this is sufficient. Desertion of a minor child is still a felony in Michigan however this really has no relation to the question as posed in relation to a divorce, where one party has moved or plans to move out of the house. The felony non-support statute in Michigan is MCL §750.164. (You may review this statute at http://legislature.mi.gov/doc.aspx?mcl-750-161.)

I do offer the following advice as an experienced litigator, attorney, divorce lawyer and compassionate human being to those who ask me the Abandonment question.

You should continue to pay the bills and support your children as you did during the marriage after you or your spouse move out of the home. For example, if you each paid certain bills, you should continue to pay the bills for which you have been responsible. Let your spouse know that you are paying those bills and you anticipate that they will continue to pay the other bills they have paid. If each of you puts money into an account and the bills are paid out of that account, you should continue to do that absent another agreement however if you are not the party that has been in “control of the checkbook” then I highly suggest that you speak to your spouse about dividing up the bills and opening separate accounts, to allow yourself the ability to open your own bank account and have some control over your own finances. Please contact me to discuss this strategy and why it is very important to do this before you or your spouse file for divorce if you can.

If you cannot pay your bills, that is an issue that you should discuss with a financial advisor, credit advisor or bankruptcy attorney, depending on the extent of the issue. I would be happy to refer you to a trusted financial advisor, credit advisor or bankruptcy attorney if you contact me online at http://camerongoulding.com/contactus.aspx. Who knows getting your financial issues in order may help your marital issues and should certainly reduce the horrible stress and anxiety that you must be facing.

North Oakland Divorce Blog: Alimony Termination - The Three Rules of Cohabitation

2010-09-08T12:26:00.000-07:00

North Oakland Divorce Blog: Alimony Termination - The Three Rules of Cohabitation

Alimony Termination - The Three Rules of Cohabitation

2010-09-08T12:23:00.000-07:00

Are you receiving or paying alimony or spousal support? Are you or your ex-husband or ex-wife “living with” a boyfriend or girlfriend? Then termination of spousal support or alimony due to cohabitation may be an issue for you.

Many judgments of divorce that include payment of alimony or spousal support include language that the alimony or spousal support will terminate if the payee (the ex-spouse receiving support) cohabits with another person of the opposite sex.

If your judgment of divorce contains this term, cohabit or cohabitation, and it does not define what that term actually means, then, in the State of Michigan, a divorce court will look at the following three factors to determine whether or not you may be able to terminate your alimony obligation or lose your right to the spousal support awarded to you:

1. The divorce court will consider the living arrangements of the couple and the extent to which they share a common residence. The divorce court will focus on factors such as whether both keep personal items such as clothes and toiletries at the residence and how long they have been doing so.

2. The divorce court will consider the couple’s personal relationship and whether it appears relatively permanent. The divorce court will look at such factors as whether the couple engages in sexual relations, vacation or spend holidays together, are monogamous and whether or not marriage has been contemplated.

3. The divorce court will consider the couple’s financial arrangements. The divorce court will look at such factors as whether the couple share expenses or whether one party supports the other.

The divorce court should not focus on any one of these factors but review the totality of the circumstances of each particular case.

If the above factors apply to you or your ex-spouse, then you should be aware that you may file a motion or your ex-spouse may file a motion to terminate alimony or spousal support. If you would like more information, please contact me to schedule an appointment at (248) 340-0900, the first half-hour is complementary or I will answer one question posted to the Contact Us page at my website http://www.camerongoulding.com/

North Oakland Divorce Blog: Michael & Diandra Douglas: why greed, anger and revenge have no place in Oakland County Divorce Courts

2010-08-25T12:18:00.000-07:00

North Oakland Divorce Blog: Michael & Diandra Douglas: why greed, anger and revenge have no place in Oakland County Divorce Courts

Michael & Diandra Douglas: why greed, anger and revenge have no place in Oakland County Divorce Courts

2010-08-24T12:12:00.000-07:00

I read in the New York Post online edition today that Michael and Diandra Douglas are once again back in a family law court, this time in New York. This unfortunate couple filed for divorce in California over ten years ago, however, this week, Diandra filed a motion in the New York divorce courts seeking half of Michael's share of the proceeds of his most recent film which is set to release in September. Ten years later and she still wants half, how can this be?

Legally, it is simple. Basically, in California (as in Oakland County Michigan, even though we are not a community property state) any income earned through the actions of one spouse during the marriage is considered joint income of the married parties. In addition, any property rights obtained through the work of either parties during the marriage is considered to be a marital property right. In the Douglas's case, it appears that Michal Douglas entered into the contract for the movie "Wall street" (a classic) and performed the role of "Gordon Gekko" while he was married to Diandra. Therefore, she was entitled to fifty percent of the proceeds from that movie.

The judgment of divorce then dictates how parties to a divorce will divide all of the income, assets and property rights earned during the marriage. This is the tricky part. Apparently, Diandra's attorneys must have included in the judgment a fifty percent share of Michael's contractual right to any "residuals, merchandising and ancillary rights" to the original movie "Wall Street". The new movie is a sequel and that's the rub. The judge in New York must now read the judgment, listen to argument and determine whether Michael and Diandra intended to include a sequel in the list of rights that she obtained to "Wall Street".

There are two lessons to be learned in this sad tale. First, the importance of a well crafted judgment of divorce that includes all foreseeable possible future issues cannot be underestimated. It is imperative to have an attorney draft this document in an exhaustive and meticulous manner, because often, as in the Douglas case, when parties continue to antagonize one another after the divorce, the decision will ultimately come down to the wording of the judgment.

The attorneys may have been able to avoid this issue by stating exactly what rights she has and what rights she does not have regarding each of his projects. For instance, according to the article, the parties argued about "spin-offs" in court as opposed to "sequels". If this is true, Michael's attorneys probably should have specifically included language stating that rights to spin-offs are included but sequels are not included. This open loop allows Diandra to get her foot in the door and proceed with legal argument. This could be an extremely expensive error for Michael if he indeed did not intend to grant the rights to sequels in the judgment of divorce.

The second issue is that this case has a byline, Michael and Diandra have a son that is now in his twenties. He is allegedly a drug dealer and has been convicted of drug related offenses. During the hearings seeking leniency for his son in recent months, Michael could not help himself, he took the opportunity to besmearch his ex-wife, blame her for their son's problems and denigrate her parenting skills in open court. This is obviously inappropriate testimony at his son's sentencing, however, Diandra made outrageous claims against Michael during the original divorce case which made him out to look like a sexual deviant. In addition, it appears that she has used the divorce court system in an attempt to punish, humiliate and extort Michael.

The point is that both of these parties started out on the wrong note and carried forward this cacophony together. They brought their anger and sense of need for vindication into court and used the courts to attempt to punish the other party and release their anger against the other party, which creates a vicious cycle indeed. Frankly, in most cases most judge (in Oakland County divorce cases at least) do not put much weight on the many wrongs that parties have committed against one another, therefore, all this serves to do is fan the flames of litigation, which in turn prolongs the proceedings and has horribly negative effects on the parties' health, finances, welfare and most importantly, their children.

Perhaps this ten year saga of misery could have been avoided. Is she had not started out trying to create scandal and misfortune or to punish him in court, or if he had decided not to hold onto his anger as shown by his recent statements at the leniency hearing, maybe they would not be in court in New York now interpreting the technical meaning of terms their attorneys put together for them in California a decade ago.

I am Cameron C. Goulding, a divorce lawyer practicing in North Oakland County Michigan for over fourteen years, for more information or to contact me please visit my website http://www.camerongoulding.com/ or call for an appointment at (248) 340-0900. I provide the highest caliber family law services to Rochester, Rochester Hills, Bloomfield, Troy, Lake Orion, Oxford, Waterford and the surrounding communities in Macomb and Genesee.

Prenuptial Agreements: The Five Requirements + Forseeability

2009-06-11T11:33:00.000-07:00

In a recent case, Reed v Reed, the Michigan Appellate Court made a decision that strengthened the enforceability of prenuptial agreements especially in long-term marriages.

Before Reed, there were five basic factors to determine whether a prenuptial agreement is enforceable:

1. Was the agreement obtained through fraud, duress or mistake?
2. Was the agreement unconscionable/unfair when signed?
3. Have the facts and circumstances changed since then so as to make it unfair and unreasonable?
4. Did both parties enter into the agreement voluntarily?
5. Did both parties disclose all assets and facts before signing the agreement?

In enforcing prenuptial agreements in long-term marriages, the Courts have typically found that the facts and circumstances had changed since the date of the agreement and refused to enforce them.

This has been generally true until the case of Reed v Reed. Mr. and Mrs. Reed married in 1975. When they married, Mr. Reed was in law school and Mrs. Reed was studying for her degree in business. They had approximately $20,000 worth of assets.

Mr. and Mrs. Reed were married for thirty years. During the marriage, they accumulated several million dollars worth of assets. They shared some of their assets and bank accounts jointly and titled other assets and bank accounts in their own names.

The trial court decided not to enforce the agreement. The trial court believed that it would be unfair to enforce the agreement at the time of the divorce based upon the length of the marriage and the accumulation of assets.

The Appellate Court disagreed with the trial court and ordered the trial court to enforce the agreement despite the length of the marriage and the accumulation of assets.

The Appellate Court included an element of "foreseeability." It indicated that at the time of the agreement, it was foreseeable that the parties may accumulate significant wealth and that a long-term marriage was as foreseeable (and actually what most people hope for) as a short-term marriage.

The court indicated that because of the "foreseeability" of the long-term marriage and accumulation of assets, enforceability was fair. It indicated that Mr. and Mrs. Reed could have foreseen the long marriage and accumulation of assets when they entered into the agreement.

The Court stated a very strong preference for upholding prenuptial agreements. It stated that the parties to the prenuptial agreement had "agreed to be captains of their own financial ship and to decide their own destiny." Therefore, if a future event is foreseeable, it is not a change that would make enforcement unfair.

This decision has strengthened the enforceability of prenuptial agreements, especially in long-term marriages. If parties that are marrying would like to maintain their own separate assets and income into the future, it appears that prenuptial agreements are a very strong way to do so.

In writing a prenuptial or making changes to one, both people should be represented by an attorney due to the serious effects it will have on their rights. Prenuptials are particularly important for small/family business owners or partners.

I am Cameron C. Goulding, a North Oakland County Divorce Lawyer, serving primarily Rochester, Rochester Hills, Bloomfield, Troy, Lake Orion and Oxford for over fourteen years. For more information or to contact me please visit my website at http://www.camerongoulding.com/ or call my office at (248) 340-0900.

Divorce and the marital residence in this rotten real estate market; four solutions

2009-06-08T11:34:00.000-07:00

The marital home or residence was once the greatest asset of the marital estate. In many cases, it has now become an albatross. Clients and potential clients are very concerned today, among other financial/economic issues, about the value of their homes in relation to the market and their mortgages. This is particularly true in areas such as Rochester and Rochester Hills where Chrysler purchased a large number of homes for executives and other employees whom are no longer living in the area and these very nice homes are sitting vacant on the market.

Many people considering divorce are concerned that, after they are divorced, they may not be able to sell the residence or, perhaps worse, may have to reside together after the divorce if they cannot sell the home. This is of a particular concern when the house is "underwater", where the appraised value of the home is less than the balance of the mortgage (or mortgage and equity loan or second mortgage.) This is known as a deficiency; the difference between the value of the home and the balance of the mortgage and often the costs associated with attempting to collect the balance.

There are at least four basic solutions to this problem.

First, the parties can attempt to work together to solve these issues. Often one party is willing to stay in the home and "ride the market out." This may require some concessions from the party that does not retain the marital home, however, if the parties can agree, this can save them from facing a certain instant deficiency where they will have to come up with money at closing from other sources of savings. In addition, characterization of payments between the parties as spousal or family support may allow the parties to take advantage of income tax differentials and overall save the parties some money in the form of taxes.

Second, the parties can sell the home at the best possible price and take money out of retirement funds to cover any deficiency. While this is not an optimal solution, it is often effective. The money can be drawn without penalty at the time of the divorce and brought to the table. This allows the parties to move on without one party bearing more risk and maintaining the mortgage payment alone.

Third, the parties may attempt to broker a short-sale of the property. In a short-sale the parties, the realtor and the bank representative work together to sell the property at the best possible price and obtain a release from the mortgage. This appears to be a good solution, however, I have heard that the length of time that it takes to complete these transactions can be significant and they appear to have a problem with falling through at the final moment.

Fourth, some clients allow the home to go into foreclosure. Unfortunately, some couples faced with divorce have homes where they cannot afford the monthly mortgage payment alone and the deficiency is so large that it does not make sense for either party to keep the home. In this situation, some clients have allowed the home to go into foreclosure. During the foreclosure period, the client usually is allowed to stay in the home even though she is not paying the mortgage. In this case, the client can save the money that would be used to pay the mortgage to apply to a new residence. Unfortunately, this leaves the couple both open to liability for the deficiency and the bank may sue either party in an attempt to recover the deficiency.

These are only four potential solutions. There are many possible ways of dealing with this issue and the divorce process can be very flexible if the parties are able to "get along" in order to move on with their lives. A solution can be fitted to every situation.

I am Cameron C. Goulding, a Divorce Lawyer practicing in Oakland County Michigan for over fourteen years. If you would like more information or to contact me please visit my website www.camerongoulding.com or call me at (248) 340-0900.