Donald J. Williams v. Linda Williams, 161 A.3d 710

Donald and Linda Williams divorced after lengthy proceedings; the District Court ordered Donald to pay $300/week interim spousal support beginning March 27, 2012.
The parties sold farm property; proceeds were split into thirds, with one third placed in escrow. Because Donald was delinquent, $5,100 was deducted from his share and given to Linda; Linda later withdrew $8,100 total (27 payments) from the escrow during an appeal.
Donald appealed the divorce judgment; Linda signed a general release in February 2014 dismissing her appeal in consideration of $50,000 from Donald; the release broadly discharged Donald from claims “growing out of or associated with the appeal.”
After dismissal of the appeal, Linda sought post-judgment relief to recover the $8,100 withdrawn from escrow; the trial court awarded her $8,100 and $6,000 in attorney fees (the latter after denying Donald’s contempt motion).
On appeal, the court vacated the $8,100 award (holding the release unambiguously barred recovery for amounts associated with the appeal) but affirmed the $6,000 attorney-fee award (finding Donald better able to pay, and any minor factual error about Linda’s income harmless).

Issue	Plaintiff's Argument (Linda)	Defendant's Argument (Donald)	Held
Whether Linda waived recovery of $8,100 withdrawn from escrow by signing the release	Release did not cover interim spousal support; she did not intend to release those payments	Release is broad and unambiguously bars recovery of amounts "growing out of or associated with the appeal"	Vacated award of $8,100; release unambiguous and bars recovery
Whether trial court abused discretion in awarding $6,000 attorney fees to Linda	Linda lacked assets/income to pay; Donald was better positioned and his company paid his bills/fees	Trial court erred (argues Linda's income finding was wrong)	Affirmed attorney-fee award; fee decision supported by totality of circumstances
Proper standard for interpreting the release	If release ambiguous, parol evidence and credibility determinations control	If release unambiguous, courts construe its plain language and cannot consider extrinsic intent	Court held the release was unambiguous and construed it per its plain terms (majority); concurrence viewed the release as ambiguous and would defer to trial court credibility findings
Effect of any clerical or minor factual errors in trial findings	Errors do not prejudicially affect the attorney-fee determination	Errors undermine fee award	Court treated minor income discrepancy as harmless error and affirmed fee award

Brochu v. McLeod, 148 A.3d 1220 (Me. 2016) (unambiguous contract language reviewed de novo)
Am. Prot. Ins. Co. v. Acadia Ins. Co., 814 A.2d 989 (Me. 2003) (contractual language is ambiguous only if reasonably susceptible to different interpretations)
Laqualia v. Laqualia, 30 A.3d 838 (Me. 2011) (effect of appeal on trial-court orders and stays)
Wandishin v. Wandishin, 976 A.2d 949 (Me. 2009) (attorney-fee awards reviewed for abuse of discretion; courts may consider relative ability to pay)
Sloan v. Christianson, 43 A.3d 978 (Me. 2012) (trial court as factfinder assesses credibility and weight of evidence)
Starrett v. Starrett, 101 A.3d 435 (Me. 2014) (harmless error doctrine for factual mistakes that do not prejudice appellant)
Barr v. Dyke, 49 A.3d 1280 (Me. 2012) (contract must be definite enough to fix legal liabilities)
2301 Cong. Realty, LLC v. Wise Bus. Forms, Inc., 106 A.3d 1131 (Me. 2014) (absolute, unequivocal release cannot be explained by parol evidence)
Norton v. Benjamin, 220 A.2d 248 (Me. 1966) (principles on construing releases)
Portland Valve, Inc. v. Rockwood Sys. Corp., 460 A.2d 1383 (Me. 1983) (ambiguous contract language permits parol evidence; interpretation is factual)
State v. Palmer, 145 A.3d 561 (Me. 2016) (ambiguities construed against the drafter)
Travelers Indem. Co. v. Bryant, 38 A.3d 1267 (Me. 2012) (rules on construing ambiguous contractual language)