Sandra Woytas v. Greenwood Tree Experts, Inc. (081720) (Morris County and Statewide)
206 A.3d 386
| N.J. | 2019Background
- Timothy and Christina Woytas divorced after an MSA that required Timothy to pay alimony and child support and to “maintain” life insurance: $400,000 naming Christina and $750,000 naming the three children (co-equal beneficiaries). A handwritten clause made the breaching party’s estate liable for "any outstanding obligations owed under this Agreement."
- The life policies Timothy purchased contained two-year suicide exclusions that limited recovery to returned premiums plus interest if he died by suicide within two years of issuance.
- Timothy remarried Sandra and purchased a $500,000 life policy naming Sandra; that policy also contained a suicide exclusion.
- Timothy committed suicide less than two years after the divorce; insurers denied face-value benefits under the suicide exclusions, paying only premiums plus interest.
- Christina (on her own behalf and for the children) and Sandra filed claims against Timothy’s estate. The estate’s assets (net) were ~$446,966; asserted claims exceeded $1.4 million.
- The Chancery Division and Appellate Division found Timothy breached the MSA by committing suicide and awarded the children priority recovery; the Supreme Court granted certification.
Issues
| Issue | Plaintiff's Argument (Christina/Children) | Defendant's Argument (Sandra/Estate) | Held |
|---|---|---|---|
| Whether Timothy’s suicide within the policies’ two-year suicide exclusion breached the MSA requirement to “maintain” life insurance | Timothy’s suicide defeated the policies’ purpose; failure to provide recoverable life insurance breaches the MSA | Suicide does not constitute a contractual breach where policies were in force; insurer’s exclusions govern recovery | Held: Suicide that prevents recovery under the policies breached the obligation to “maintain” insurance; Timothy failed to maintain effective coverage |
| Proper measure and distribution of damages from the estate after breach | Children entitled to recover outstanding obligations under MSA; estate liable for unpaid child support and related obligations; priority over other claims | Estate (Sandra) argued recovery should be limited to actual outstanding periodic payments over time, not policy face value; contended her claims have priority | Held: MSA’s handwritten remedy covers “any outstanding obligations”; precise future-damages calculation would be speculative; Chancery did not abuse discretion in concluding outstanding obligations exceed estate assets; no remand needed |
| Whether the requirement to maintain life insurance is a child-support order with priority | Life-insurance requirement secures child-support obligations and has priority | Sandra did not contest priority on appeal but previously disputed priority vis-à-vis her claim | Held: Requirement constitutes child-support security; children’s claim has priority under applicable New Jersey law (not disputed on appeal) |
| Need for remand to calculate exact damages | Plaintiffs: remand unnecessary because obligations exceed estate value | Sandra: remand appropriate to compute exact outstanding obligations and allocations | Held: No remand — given substantial obligations and limited estate assets, precise calculation unnecessary as estate insufficient to satisfy Sandra’s claims |
Key Cases Cited
- Tintocalis v. Tintocalis, 25 Cal. Rptr. 2d 655 (Ct. App. 1993) (holding procurement of policy with suicide exclusion that prevents beneficiary recovery is not equivalent to "maintaining" life insurance)
- Terry v. Terry, 788 So. 2d 1129 (Fla. Dist. Ct. App. 2001) (contrasting outcome where enforcement delay affected wife’s recovery under insurance obligation)
- Brill v. Guardian Life Ins. Co. of Am., 142 N.J. 520 (1995) (summary judgment standard)
- Quinn v. Quinn, 225 N.J. 34 (2016) (MSA interpretation follows ordinary contract principles)
- Globe Motor Co. v. Igdalev, 225 N.J. 469 (2016) (elements for breach of contract)
- Pickett v. Lloyd’s, 131 N.J. 457 (1993) (breaching party liable for natural and probable consequences of breach)