Poli, A. v. Poli, L., 1989 WDA 2015

Husband and Wife divorced after separating in 2004; economic claims were tried before a Master in 2007 and remanded for valuation of Husband’s inheritance interest from his mother’s estate.
A 2009 Consent Order resolved exceptions by requiring Husband to pay Wife a sliding-scale sum based on his “net inheritance” from his mother’s estate, with a minimum $50,000 payable even if the inheritance was minimal or zero; the Estate was to pay Wife directly prior to distributions to Husband.
The disputed real estate asset sold at a tax sale in 2013 for roughly the tax amount; the Estate closed on March 10, 2014, and Husband received no substantial net inheritance from that sale.
Wife filed an enforcement petition in February 2015 seeking $120,000 but reduced her request to $50,000 after conciliation; the trial court granted enforcement (award: $50,000 plus $3,000 counsel fees).
Husband appealed, arguing the Consent Order was not a continuing contract, that the statute of limitations and doctrines of laches and equitable estoppel bar enforcement, that parol evidence was improperly admitted, and that Wife had already received her share during the marriage.

Issue	Wife's Argument	Husband's Argument	Held
Whether the Consent Order is enforceable and not time-barred	Consent Order is a continuing contract tied to Husband’s “net inheritance” and triggering event was estate closing; petition filed within 4 years of closing	Consent Order was final in 2009; statute of limitations expired in 2013	Court held Consent Order was a continuing contract; petition timely within 4 years of estate closing
Whether parol evidence was improperly admitted	Court relied on plain, unambiguous language; did not need parol evidence	Parol evidence should not have been admitted or relied upon	Court found language unambiguous and did not rely on parol evidence; no error
Whether laches bars enforcement	No undue delay; Wife acted promptly after estate closed and suffered no prejudice to Husband	Wife slept on her rights by waiting over five years to enforce, causing prejudice	Court found no laches: Wife inquired shortly after closing and filed within eight months; Husband showed no prejudice
Whether equitable estoppel or prior payments satisfied Wife’s claim	Consent Order controls; prior testimony at Master did not supersede the Order	Wife’s conduct and past receipt of money during marriage indicate she waived further claim or Husband already paid his share	Court rejected estoppel/satisfaction arguments; Consent Order required payment and Husband admitted minimum $50,000 obligation if inheritance < $200,000

Lee v. Lee, 978 A.2d 380 (Pa. Super. 2009) (standard of appellate review for equitable distribution)
Anzalone v. Anzalone, 835 A.2d 773 (Pa. Super. 2003) (trial court’s broad equitable powers and deference to factual findings)
Lang v. Meske, 850 A.2d 737 (Pa. Super. 2004) (contract interpretation and when parol evidence is admissible)
K.A.R. v. T.G.L., 107 A.3d 770 (Pa. Super. 2014) (continuing contract test and statute of limitations accrual)
Miller v. Miller, 983 A.2d 736 (Pa. Super. 2009) (continuing contracts in family law context)
Fulton v. Fulton, 106 A.3d 127 (Pa. Super. 2014) (doctrine of laches: delay plus prejudice required)
Guerra v. Redevelopment Auth. of City of Philadelphia, 27 A.3d 1284 (Pa. Super. 2011) (elements of equitable estoppel)