Sean Thomas Ryan v. Dee Anna Ryan, 972 N.E.2d 359

Sean and Dee Anna Ryan dissolved their marriage and agreed to sell two jointly owned properties with minimum net-proceeds floors.
A Private Agreement allowed either party to bind the other to accept offers only if net proceeds meet specified minimums: $1,100,000 for Granger residence and $300,000 for lake house.
The Property Settlement Agreement, incorporated into the divorce decree, required payment of mortgages, taxes, and insurance until sale and specified cost-sharing.
When sales did not occur as planned by May 2010, Sean moved for relief under Indiana Trial Rule 60(B)(8) to have the properties sold at prevailing fair market value.
The trial court denied relief; the Court of Appeals reversed, prompting the Indiana Supreme Court to decide the scope of modification vs. interpretation of property-disposition agreements and the availability of Rule 60 relief.
The Court ultimately held that the minimum-net-proceeds provisions were not modifiable by the court and that Sean’s requested relief would effectively modify the contract, which is prohibited absent fraud, duress, or agreement, and that Rule 60(B)(8) relief is not available here.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a court modify a property-disposition agreement without both parties’ consent?	Ryan seeks modification of the minimum net-proceeds terms.	Dee Anna contends the agreement is unmodifiable by court order.	No modification without consent or fraud/duress.
May the court interpret/clarify the agreement as contract interpretation rather than modification?	Sean argues for clarification to enforce their stated intention to sell.	Dee Anna argues for normal contract interpretation without rewriting terms.	Contract-interpretation analysis governs; no rewriting of the minimums.
Is Trial Rule 60(B)(8) relief available to grant extrinsic modification of the agreement?	Rule 60(B)(8) provides equitable relief to achieve relief from judgment.	Such relief would modify the contract and is not permitted.	Rule 60(B)(8) relief not available to modify the agreement.
Do authorities allowing relief under Rule 60(B) apply to real estate dispositions like this case?	Sean cites Dusenberry and Brownsing for equitable relief.	These cases do not support altering a fixed minimum-proceeds provision.	Not applicable to compel sale below minimums; relief denied.

Johnson v. Johnson, 920 N.E.2d 253 (Ind. 2010) (modification of property settlements requires consent or fraud/duress; not open-ended modification)
Voigt v. Voigt, 670 N.E.2d 1278 (Ind. 1996) (unambiguous prohibition on modifying property-disposition settlements; limited to fraud/duress or agreement)
Dusenberry v. Dusenberry, 625 N.E.2d 458 (Ind. Ct. App. 1993) (Rule 60(B) relief does not override contract terms for property division; mutual-mistake discussion not controlling here)
Niccum v. Niccum, 734 N.E.2d 637 (Ind. Ct. App. 2000) (growth/ loss in investment plans shared absent express language; not applied to real estate)