L.F. v. J.F., Sr.
L.F. v. J.F., Sr. No. 1744 MDA 2016
| Pa. Super. Ct. | Jul 31, 2017Background
- Wife and Husband executed a post-nuptial Agreement in 2007 governing spousal support and allocation of unreimbursed medical expenses; a 2009 court order adopted $2,000/month spousal support from Husband and left the Agreement controlling other terms.
- The Agreement incorporated a June 18, 2007 Recommended Order that required documentation of unreimbursed medical expenses to be provided to the other party no later than March 31 of the year following the calendar year in which the final bill was received, and allocated bills 91% to Husband and 9% to Wife.
- Wife submitted unreimbursed medical bills spanning 2007–2015 to Domestic Relations in January 2016; Domestic Relations declined enforcement because the 2009 order did not address medical expenses.
- Wife filed an Enforcement Petition in February 2016; at the June 16, 2016 hearing the parties submitted briefs and the trial court received no testimonial evidence of when Husband received notice of the bills.
- The trial court found Wife failed to give timely notice for bills from 2007–2014 per the Agreement/Recommended Order and limited further proceedings to 2015 bills; Wife’s motion for reconsideration was denied and she appealed.
Issues
| Issue | Wife's Argument | Husband's Argument | Held |
|---|---|---|---|
| Did Wife timely provide notice of unreimbursed medical expenses? | Wife contends she has evidence showing she notified Husband timely. | Husband (and trial court) point to lack of any evidence presented at the hearing proving timely notice. | Trial court not reversed: no evidence in certified record showing timely notice; appellate review limited to record. |
| Does the Agreement impose a time limit for providing medical-bill documentation? | Wife argues Agreement controls only notice timing, not enforcement timing; relies on Rule 1910.16-6(c)(3) to avoid a strict cutoff. | Agreement and Recommended Order require documentation to be provided by March 31 following the calendar year; parties bound by contract terms. | Court enforces the Agreement/Recommended Order deadline; timely notice is required. |
| Did the trial court lack authority to enforce older (2007, 2008, 2009, 2014) bills? | Wife asserts court should have considered and allocated those older bills per the Agreement. | Trial court says allocation discretionary and untimely bills need not be enforced absent timely notice. | Court held allocation of untimely bills is within trial court discretion and denial was not an abuse of discretion. |
| Should untimely medical bills be allocated per the Agreement despite Rule 1910.16-6(c)(3)? | Wife reads the Rule to allow enforcement regardless of prior domestic relations submission deadlines. | Trial court reads the Rule in context: timely notice to the other party is required; Rule preserves court discretion to deny allocation of untimely documentation. | Court rejected Wife’s Rule-based argument and affirmed reliance on the Agreement and the Rule’s discretionary language. |
Key Cases Cited
- Lugg v. Lugg, 64 A.3d 1109 (Pa. Super. 2013) (post-nuptial agreements treated as contracts; review for abuse of discretion)
- W.A.M. v. S.P.C., 95 A.3d 349 (Pa. Super. 2014) (support-order review limited; reversal only for abuse of discretion)
- Simeone v. Simeone, 581 A.2d 162 (Pa. 1990) (spouses generally bound by clear marital agreements absent fraud/duress)
- In re Estate of Johnson, 970 A.2d 433 (Pa. Super. 2009) (enforcement of unambiguous agreement terms despite conflicting statutory expectations)
- Nicolaou v. Martin, 153 A.3d 383 (Pa. Super. 2016) (court may consider reproduced-record documents when undisputed)