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Coleman v. Robinson

Citations: 746 So. 2d 65; 98 La.App. 4 Cir. 1874; 1999 La. App. LEXIS 2426Docket: No. 98-CA-1874

Court: Louisiana Court of Appeal; September 1, 1999; Louisiana; State Appellate Court

Narrative Opinion Summary

In a complex matrimonial property case, the trial court dismissed a Petition for Supplemental Partition filed by the appellant, who sought additional partition of unallocated pension rights following a 1987 Separation, Support, and Property Settlement Agreement with her former spouse. The parties, married in 1955 and separated in 1986, had previously executed an agreement under North Carolina law, which the court found to have effectively partitioned all marital property, including pension rights. The appellant challenged this interpretation, arguing that her former spouse had failed to designate her as a beneficiary and had committed fraud and breached fiduciary duties. The trial court found no merit in these claims, emphasizing the appellant's legal representation and the agreement's clear language. The appellate court reviewed the case for legal errors, upholding the trial court's application of North Carolina law and its findings on the credibility of the parties. The appellant's claims for attorney's fees and enforcement of certain agreement provisions were likewise dismissed. The judgment was affirmed in full, with a dissenting opinion suggesting remand for further consideration.

Legal Issues Addressed

Application of Chosen Law in Separation Agreements

Application: The court applied North Carolina law to the Separation, Support, and Property Settlement Agreement, as specified in the agreement itself.

Reasoning: The agreement specifies that it is governed by the laws of North Carolina, as stated in Paragraph 13.

Breach of Fiduciary Duty and Fraud Claims

Application: The court dismissed claims of fraud, bad faith, and breach of fiduciary duty against the husband, noting the wife's legal representation and awareness of the agreement.

Reasoning: The trial judge, having observed the witnesses, found Mr. Robinson credible and concluded that there was no evidence of wrongdoing on his part.

Definition of Marital Property under North Carolina Law

Application: The court determined that retirement benefits, including vested pension and retirement rights, qualify as marital property acquired during the marriage under North Carolina law.

Reasoning: According to North Carolina General Statute 50-20, retirement benefits sought by Ms. Coleman qualify as marital property, as they were acquired during the marriage.

Enforcement of Property Settlement Agreements

Application: The court found that the property settlement agreement effectively divided all marital property, including pension rights, and therefore denied Coleman's claim to unpartitioned pension rights.

Reasoning: Ms. Coleman's claim that her husband's retirement benefits were not partitioned lacks credibility, given the agreement's clear language on property division.

Termination of Alimony Obligations

Application: The court found that the husband's obligation to pay alimony ended upon the wife's remarriage, as stipulated in the agreement.

Reasoning: Upon her remarriage, Mr. Robinson's obligation to pay alimony ceased, which implied that his requirement to select Option B of the Government Retirement Plan also ended.