Woodward v. Ehrler-Nugent (In re Nugent), 484 B.R. 671

Divorce between Samuel Woodward and Susan Ehrler-Nugent; Alabama state court awarded the marital home to Debtor and required her to pay the home loan and indemnify Plaintiff, plus a $14,000 payment to Plaintiff.
Debtor later filed Chapter 7; Plaintiff sought a declaratory judgment that the Debtor’s obligations under the Alabama judgment are non-dischargeable as domestic support obligations under § 523(a)(5).
HELOC on Lagoon Drive existed; Debtor made some payments post-judgment but stopped, causing Wells Fargo to expect Plaintiff to pay; HELOC balance approx. $93,000.
Paragraphs six and seven of the Judgment respectively addressed the property award and the $14,000 payment; no alimony was expressly awarded.
Main case posture: Plaintiff’s complaint argued for non-dischargeability under § 523(a)(5); Debtor argued obligations are not domestic support and may be property division under § 523(a)(15); Court ultimately found the obligations are not domestic support obligations and are discharged.
Court noted pleading error: only § 523(a)(5) was pled, § 523(a)(15) was not; extrinsic evidence (Nunnally factors) considered but did not establish domestic support obligation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the Obligations domestic support obligations under § 523(a)(5)?	Plaintiff contends the Obligations are alimony/support despite the Judgment saying no alimony.	Debtor argues the Obligations are not alimony, maintenance, or support.	Ambiguous; court held the Obligations are not established as domestic support obligations under § 523(a)(5).
Should extrinsic evidence (Nunnally factors) be used to classify the Obligations because the Judgment language is unclear?	Plaintiff relies on extrinsic factors to show intent to create support.	Court should avoid extrinsic factors if language is clear; Extrinsic evidence only if ambiguity persists.	Extrinsic evidence considered, but the court found the language and intent not clearly domestic support; ultimately not dischargeable under § 523(a)(5).
Was the court constitutionally authorized to enter final judgment under Stem v. Marshall?			Court held Stem v. Marshall distinguishable and authorized to enter final judgment.
If only § 523(a)(5) is pled, can § 523(a)(15) govern dischargeability of the obligations?	Plaintiff sought non-dischargeability under § 523(a)(5) only.	§ 523(a)(15) not pled, thus not applicable; classification under § 523(a)(5) controls.	Court denied amendment to plead § 523(a)(15); obligations not discharged under § 523(a)(5).

In re Dennis, 25 F.3d 274 (5th Cir. 1994) (labels not dispositive; ultimate characterization is under bankruptcy law)
In re Evert, 342 F.3d 358 (5th Cir. 2003) (Nunnally factors used only when decree language is ambiguous)
In re Nunnally, 506 F.2d 1024 (5th Cir. 1975) (set of factors to determine intent of decree in domestic support cases)
In re Davidson, 947 F.2d 1294 (5th Cir. 1991) (binding principle to consider the intent of the divorce decree creator)
In re Gianakas, 917 F.2d 759 (3d Cir. 1990) (principles on characterization of obligations arising from divorce)
Stem v. Marshall, 131 S. Ct. 2594 (2011) (limits on constitutional authority of bankruptcy courts; final-order authority)