Springer v. YoungSpringer v. Young
MEMORANDUM OPINION
Pending before the Court is a Motion to Dismiss and Motion for Judgment on the Pleadings1. On April 3, 2026, Eric Stanley Young (the “Defendant“) filed a motion under
contends she is entitled to judgment on the pleadings because the Defendant admitted his obligation is non-dischargeable before the Family Court of Berkeley County, West Virginia (the “Family Court“).
For the reasons stated herein, the Court will deny the Defendant‘s Motion to Dismiss and deny the Plaintiff‘s Motion for Judgment on the Pleadings.
I. STANDARDS OF REVIEW
To survive a
Under
II. BACKGROUND
On January 25, 2019, in a divorce hearing before the Family Court, Attorney Gregory A. Bailey, the Plaintiff‘s divorce attorney, referring to the obligation at issue, stated, “I don‘t know if it‘s in the agreement, it‘s -- I think we contemplated it‘s a domestic support obligation not dischargeable in bankruptcy.” In response, Attorney Christopher Janelle, the Defendant‘s divorce attorney, stated “I would agree with that, the representation, that as a matter of law it is, -- and if we need to put that in the final order, I will agree to do that.” Attorney Janelle further stated, “In other words, the payment -- the рayment can‘t be, -- it‘s not subject to bankruptcy.”
On January 29, 2019, the Family Court awarded the Plaintiff $227,000.00 in a final divorce order (the “Divorce Order“). Section (J) of the Divorce Order set forth:
That in order to equalize equitable distribution, Respondent shall pay to the Petitioner the sum of $227,000.00, as follows: $15,000.00 cash within thirty (30) days, payoff of Petitioner‘s vehicle in the amount of $6,000.00 immediately, and the remaining amount of $206,000.00 shall be paid over a period of 120 months at 5.5% interest, beginning February 2019, by the 15th of each month, in the amount of $2,236.90. This payment shall be deemed a domestic support obligation.
Section (K) of the Divorce Order further set forth, in part, “[a]ccordingly, no award of spousal support shall be made and the parties are forever barred from asserting a claim for spousal support in the future.”
On January 4, 2024, the Defendant filed a voluntary petition for relief under Chapter 13 of the Bankruptcy Code, along with the required schedules and a plan of reorganization. The Defendant‘s plan treated the Plaintiff‘s claim as a general unsecured debt аrising from a divorce proceeding. The Plaintiff filed Claim No. 12-1 for $155,527.40, listing the basis of the claim as “[e]quitable distribution from divorce.” The Plaintiff did not object to the Defendant‘s plan. On January 20, 2025, the Court confirmed the Defendant‘s Chapter 13 plan. On March 3, 2026, the Plaintiff filed this adversary proceeding through her Complaint seeking to have her claim exempted from discharge under
III. DISCUSSION
The Defendant filed the pending Motion to Dismiss alleging the Plaintiff‘s Complaint fails to allege sufficient facts that establish the Plaintiff‘s claim is a non-dischargeable domestic support obligation defined by
Here, the Plaintiff‘s Complaint alleges enough facts to plausibly support a claim under
A. The Plaintiff‘s Complaint survives the Defendant‘s Motion to Dismiss.
The analysis for whether an obligation is alimony, maintenance, or support is fact-specific and the bankruptcy court “must not rely on the label used by the parties or the state court but must look beyond the label to examine whether the debt actually is in the nature of support or alimony.” Lawrence v. Combs (In re Combs), 543 B.R. 780, 794 (Bankr. E.D. Va. 2016) (citing Cummings v. Cummings, 244 F.3d 1263, 1265 (11th Cir. 2001)). “The substance of the agreement rather than the terms affixed to it controls the nature of the obligation.” Tilley v. Jessee, 789 F.2d 1074, 1077 (4th Cir. 1986). Courts primarily look to the parties’ intent in creating a support obligation. In in
(1) The actual language and substance of the agreement; (2) the financial situation of the parties at the time of the agreement, including their prospects for future income; (3) the function served by the obligation at the time of the agreement; and (4) whether there is any evidence of overbearing at the time of the agreement that would cause the court to question the intent of a spouse.
In re Bailey, No. 09-2564, 2010 WL 4622455 (Bankr. N.D.W. Va. Nov. 4, 2010); Kettner v. Kettner, No. CIV.A. 91-587-N, 1991 WL 549386 (E.D. Va. Nov. 19, 1991).
In the alternative,
Here, dismissal is not appropriate because the Plaintiff has plausibly alleged facts supporting non-dischargeability under
Second, Count II of the Plaintiff‘s Complaint alleges her claim is non-dischargeable because the Divorce Order ordered the Defendant pay the Plaintiff $227,000.00 “in order to equalize equitable distribution” and labeled it “a domestic support obligation.” Although the Defendant requests that the Court “dismiss the Complaint in its entirety,” he “does not dispute that
B. Judgment on the Pleadings is not appropriate because neither res judicata nor collateral estoppel apply.
The Full Faith and Credit Act,
(1) The issue previously decided is identical to the one presented in the action in question; (2) there is a final adjudication on the merits of the prior action; (3) the party against whom the doctrine is invoked was a party or in privity with a party to a prior action; and (4) the party against whom the doctrine is raised had a full and fair opportunity to litigate the issue in the prior action.
Syl Pt. 1, State v. Miller, 459 S.E.2d 114, 117 (1991). Notably, “a default judgment is equivalent to a final judgment on the merits.” Stillwell v. City of Wheeling, 558 S.E.2d 598, 605 (W. Va. 2001).
Whether an obligation is “in the nature of alimony, maintenance, or support,” as required for it to qualify as “domestic support obligation” under the Bankruptcy Code, is a question of federal, not state law. Lawrence, 543 B.R. at 793. The language used or approved by a state court does not control whether an obligation is non-dischargeable because federal bankruptcy law prevails in determining whether an obligation is alimony, support, or a property settlement. In re Carbia, 113 B.R. 761, 763 (Bankr. S.D. Fla. 1990) (citing In re Basile, 44 Bankr. 221 (Bankr. M.D. Fla. 1984)); see also 1 Collier Family Law and the Bankruptcy Code P 6.04 (2026) (“It is firmly estаblished that a court determining whether an obligation is alimony, maintenance, or support for bankruptcy dischargeability purposes is not bound by the label given to the obligation in the agreement or order that created it“); see also In re Werthen, 329 F.3d 269, 273 (1st Cir. 2003) (“The federal courts have been unwilling to treat the label applied by the divorce court as controlling for Bankruptcy Code purposes“). “Parties may not agree in advance, contrary to the provisions of the Bankruptcy Code, that a debt will be non-dischargeable in a bankruptcy case, and, therefore, no method of labeling obligations in an agreement can be used to assure that result.” 1 Collier Family Law and the Bankruptcy Code P 6.04 (2026); see also In re Catron, 164 B.R. 912 (E.D. Va. 1994), aff‘d, 43 F.3d 1465 (4th Cir. 1994) (Finding that although the parties divorce settlement agreement stated the debt was “in the nature of support, alimony, and maintenance” and “exempt from discharge and non-dischargeable in bankruptcy,” the bankruptcy court properly conducted an independent analysis to determine dischargеability).
Here, neither res judicata nor collateral estoppel apply to this adversary proceeding. Res judicata is inapplicable because as explained in Brown, res judicata is inapplicable in the bankruptcy non-dischargeability context. Collateral estoppel is inapplicable becаuse the Family Court did not actually litigate or decide the issue presently before this Court, which is whether the Defendant‘s obligation is dischargeable under
The Plaintiff‘s reliance on In re Santos is misplaced. In re Santos is distinguishable because the bankruptcy court relied upon the debtor‘s answer to an adversary complaint that admitted the plaintiff held a domestic support obligation under
As set forth above, whether a debt is non-dischargeable under
C. The Court declines to address timeliness of the Plaintiff‘s Complaint.
In her Response to the Defendant‘s Motion to Dismiss, the Plaintiff addresses the timeliness of her Complaint. Specifically, the Plaintiff states that the Plaintiff‘s counsel inadvertently caused “a two-month delay in the filing of the adversary proceeding.” Although never raised by the Defendant in his Motion to Dismiss, the Court is unaware of any basis that the Complaint is untimely. Therefore, it is unnecessary for the Court to rule on the timeliness of the Complaint.
IV. CONCLUSION
For the foregoing reasons, the Court finds it appropriate to deny Defendant Eric Stanley Young‘s Motion to Dismiss and deny Plaintiff Diana Grace Springer‘s Motion for Judgment on the Pleadings. Consistent with
David L. Bissett
United States Bankruptcy Judge