Victor Vasquez v. Diane Kownacki, 73038-0

Victor Vasquez and Diane Kownacki divorced in 2009; the decree awarded Vasquez a $115,000 judgment secured by a deed of trust on the family home and ordered Kownacki to receive $600/month child support.
Kownacki fell behind on mortgage payments; in July 2012 Vasquez signed and notarized a document titled “satisfaction of judgment” acknowledging full satisfaction of the $115,000 judgment; it was filed with the court in August 2012.
Vasquez later moved out of state and failed to pay child support; in 2014 he moved to enforce the judgment, claiming he signed the satisfaction in reliance on an oral agreement that Kownacki would pay him $115,000 (and sought offset for unpaid child support).
Kownacki submitted a declaration denying any promise to pay and explaining Vasquez signed to allow refinancing and to “call it even.” Emails between Vasquez and a title company were also submitted.
A commissioner treated the satisfaction as an unambiguous written instrument and denied relief; the trial court denied revision for “failure of proof,” finding insufficient extrinsic evidence to set aside the satisfaction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extrinsic evidence could be used to vacate a satisfaction of judgment	Vasquez: satisfaction was part of an oral contract; extrinsic evidence shows a promise that Kownacki would pay $115,000	Kownacki: satisfaction is an unqualified written instrument and no promise was made; the record lacks proof of fraud/duress/condition	Court: Trial court considered extrinsic evidence and found it insufficient; satisfaction not set aside
Burden and standard to vacate a satisfaction of judgment	Vasquez: he met the burden by producing declarations and emails	Kownacki: Vasquez failed to prove grounds (fraud, duress, mistake, nonperformance)	Court: Plaintiff bears burden; substantial evidence supports denial
Whether appellate review should target the commissioner or trial court ruling	Vasquez: challenges both commissioner and trial court for not considering extrinsic evidence	Kownacki: trial court reviewed the record and ruled appropriately	Court: Review focuses on trial court; it properly considered evidence and credibility determinations are deferred to trial court
Whether offset for unpaid child support should alter outcome	Vasquez: asked for offset of ~ $26,000 in unpaid child support against judgment	Kownacki: no offset shown because satisfaction stands and no enforceable agreement to pay	Court: No relief granted; failure of proof on the foundational claim meant no offset granted

State v. Ramer, 151 Wn.2d 106 (2004) (appellate review addresses the trial court’s ruling rather than a commissioner’s)
In re Marriage of Rideout, 150 Wn.2d 337 (2003) (appellate review defers to trial court credibility determinations and requires substantial evidence)
Griggs v. Morgan, 4 Wn. App. 468 (1971) (party seeking to set aside a satisfaction of judgment must prove grounds such as fraud, duress, undue influence, or nonperformance)