Kaftan v. Kaftan, 300 Mich. App. 661

Settlement agreement from December 29, 2001 required Melvin to make payments to Carole through 2017 totaling $7,704,000.
Melvin retained most real estate; there was no valuation of the estate in the agreement.
Melvin stopped payments in 2009; litigation ensued with Carole seeking remaining payments and Melvin seeking modification or rescission.
Melvin claimed third-party fraud by a business partner causally affected asset valuation; he asserted mutual mistake defenses.
Trial court granted Carole summary disposition, finding statute of limitations and laches bar the claim and no mutual mistake; Melvin appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mutual mistake exists	Melvin argues error in valuation via third-party fraud justifies mutual mistake.	Carole contends no mutual mistake due to finality provisions and lack of equal division intent.	No mutual mistake; agreement final and not subject to correction for third-party fraud.
Whether statute of limitations or laches bars claim	Melvin asserts possible tolling or discovery-based relief.	Carole maintains time-bar and laches apply.	Court affirmed; limitations/laches bar relief.
Whether sanctions were warranted	Melvin's conduct merited sanctions for frivolous arguments.	Carole sought sanctions due to perceived frivolity; court should impose if warranted.	Sanctions not warranted; trial court did not abuse discretion.

Ford Motor Co v City of Woodhaven, 475 Mich 425 (2006) (mutual mistake framework and evaluation guidance)
Marshall v Marshall, 135 Mich App 702 (1984) (modification denied when mistake concerns post-settlement value change)
Smith v Smith, 292 Mich App 699 (2011) (no contractual adjustment for market fluctuations absent explicit terms)
Simkin v Blank, 19 NY3d 46 (2012) (Ponzi-related value loss not mutual mistake; reliance on finality and explicit terms)
Kitchen v Kitchen, 465 Mich 654 (2002) (sanctions standard and complexity of issues related to preservation of fairness)