Belinda Butler Pandey v. Aneel Madhukar Pandey, M2016-01919-COA-R3-CV

Married 15 years; three children (two with special needs). Parties executed a postnuptial agreement on Dec. 17, 2011 addressing property division, child support, and waivers of alimony; it included a prevailing-party attorney’s fee clause for enforcement/defense of the Agreement.
Wife filed for divorce in Jan. 2013 and sought enforcement of the Agreement; Husband repeatedly contested the Agreement’s validity (fraud, duress, misrepresentation, collusion) and filed many motions, including two recusal motions.
Trial spanned multiple days in Jan. 2015; trial court found Wife and other witnesses credible, found Husband not credible, and held the Agreement valid and enforceable.
The trial court enforced the Agreement’s property division and child-support provisions, applied the Guidelines, and permitted an upward deviation for the children’s special needs.
Under the Agreement’s fee clause, the court awarded Wife attorney’s fees for enforcing/defending the Agreement, then reduced the award on motion; Husband appealed, arguing (inter alia) error in the fee award and in denial of recusal.

Issue	Plaintiff's Argument (Wife)	Defendant's Argument (Husband)	Held
1. Entitlement to contractual attorney’s fees	Wife sought fees under the Agreement as prevailing party enforcing/defending it.	Husband argued Wife contested parts (child support) and therefore cannot invoke the fee clause.	Court: Wife consistently sought enforcement; invoking Guidelines was alternative; fee clause applies — entitlement affirmed.
2. Reasonableness / amount of attorney’s fees awarded	Wife sought full fees incurred.	Husband argued fees should be denied or reduced because Wife contested parts of Agreement.	Court: Trial court has discretion to determine reasonable amount under contract; no abuse of discretion in partial award; award upheld (reduced amount affirmed).
3. Trial judge recusal	Wife defended denial of recusal; judge’s remarks and rulings were within adversarial context.	Husband asserted bias/prejudice based on comments and repeated adverse rulings; sought recusal and transfer.	Court: Recusal not warranted; isolated remark (“messing with you”) and adverse rulings do not show extrajudicial bias; denial affirmed.
4. Attorney’s fees on appeal / procedural waiver	Wife sought fees on appeal under §27-1-122 and Agreement, calling appeal frivolous.	Husband sought to raise multiple issues; Wife argued waiver of some issues due to deficient brief.	Court: Appeal not frivolous; no appellate fee award; briefing deficiencies noted but court waived formal defects to decide merits.

McCarty v. McCarty, 863 S.W.2d 716 (Tenn. Ct. App. 1992) (standard of review for factual findings on appeal)
Allstate Ins. Co. v. Watson, 195 S.W.3d 609 (Tenn. 2006) (contract interpretation principles; ambiguity and use of parol evidence)
Young v. Barrow, 130 S.W.3d 59 (Tenn. Ct. App. 2003) (treatment of pro se litigants and brief standards)
Davis v. Liberty Mut. Ins. Co., 38 S.W.3d 560 (Tenn. 2001) (recusal standard; when judge’s impartiality may reasonably be questioned)
Chiozza v. Chiozza, 315 S.W.3d 482 (Tenn. Ct. App. 2009) (discretion to waive briefing requirements to reach merits)
Farmers-Peoples Bank v. Clemmer, 519 S.W.2d 801 (Tenn. 1975) (when contractual language is ambiguous)
Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (recusal and appearance-of-bias principles)