Laqualia v. Laqualia
2011 ME 114
| Me. | 2011Background
- Karen and John executed a premarital agreement on August 16, 1994, and married eleven days later.
- Karen entered the marriage with a substantial premarital estate (> $2,000,000); John had a modest premarital estate (~$20,000).
- During the marriage, Karen developed PeakKnowledge with John assisting; income and assets from Karen’s arrangements funded a lavish lifestyle.
- In 2007 Karen filed for divorce; after lengthy litigation, the May 2010 trial addressed only property issues and the premarital agreement was found enforceable.
- The court divided assets, awarding Karen certain nonmarital property and marital assets, and required Karen to pay John $300,000 to achieve an equitable distribution, which the court later concluded was in error and vacated on remand.
- Following the divorce judgment, Karen appealed, and separately moved to enforce a preliminary injunction regarding health insurance; the trial court held it lacked jurisdiction during the appeal but some aspects were not stayed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valuation and distribution of PeakKnowledge and related assets | Laqualia contends valuation/distribution mischaracterized as marital assets. | Laqualia argues court correctly valued assets and applied the premarital agreement. | Valuation supported; remanded for equitable distribution consideration of marital estate. |
| Effect of premarital agreement on nonmarital property and distribution | Karen asserts nonmarital assets should be treated as her property, not divisible. | Premarital agreement enforces separation of property; nonmarital assets not subject to equal distribution. | Premarital agreement enforced; nonmarital assets set apart; remaining marital assets divided, with remand on exact equitable distribution amounts. |
| Authority to consider post-appeal motion to enforce preliminary injunction | Trial court should address enforcement of the injunction during appeal. | Court lacked jurisdiction to enforce during pendency of appeal unless stayed. | Court lacked jurisdiction to enforce during appeal; health-insurance provision not stayed as judgment ended obligation; discretion to restore injunction discussed but denial affirmed. |
| Attorney fees | Fees should be awarded based on litigation conduct and need. | Each party bore their own fees due to conduct and complexity. | No abuse of discretion; each party to pay own attorney fees. |
Key Cases Cited
- Bond v. Bond, 2011 ME 54 (Me. 2011) (review of asset valuation and property division requires support by competent evidence)
- Grishman v. Grishman, 407 A.2d 9 (Me. 1979) (three-step framework for distribution of marital property)
- Spooner v. Spooner, 2004 ME 69 (Me. 2004) (equal division not necessarily equitable in distribution)
- Doucette v. Washburn, 766 A.2d 578 (Me. 2001) (evidence and valuation considerations in property division)
- Palacci v. Palacci, 613 A.2d 951 (Me. 1992) (premarital agreement and nonreliance on spousal-support exceptions)
- Adams v. Adams, 620 A.2d 286 (Me. 1993) (appellate stay and enforceability issues in family judgments)
- Most v. Most, 477 A.2d 250 (Me. 1984) (stability of stays during appeal in family cases)
- Levasseur v. Levasseur, 2010 ME 5 (Me. 2010) (health insurance and support considerations in divorce context)