Pattison v. Pattison (2023) & Deadline Contingencies for Settlements

Pattison v. Pattison (2023) & Deadline Contingencies for Settlements

In many ways, marital settlement agreements are treated just like other contracts in the State of Maryland. If we think of these specialized agreements as “just another contract,” this will shed light on how courts view and approach these agreements. If issues arise as to the validity or enforceability of these agreements, Maryland courts will utilize principles derived from basic contract law when they attempt to resolve these issues.

The case of Pattison v. Pattison (2023) is a recent case which involved the issue of acceptance deadlines in marital settlement agreements. In this case, the wife offered certain terms as part of a settlement agreement, but included a “condition precedent” that the offer must be accepted by a deadline. This type of issue is bound to come up frequently when dealing with these agreements. Let’s look at the details of this case carefully to understand how the court will approach this matter.

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Facts of the Case

The couple in this case was married for about three years. The divorce proceedings initially commenced in 2019. The wife obtained an attorney who assisted her during the creation of the marital settlement agreement. The wife developed a proposed agreement which she sent to the husband through her counsel. The agreement included a deadline for acceptance: if the husband didn’t accept (i.e. sign) the agreement by the end of the same day on which the agreement was sent, the agreement would expire. In other words, if the husband failed to sign by the end of that same day, the wife would effectively “revoke” the settlement agreement. The husband signed several days later.

After the husband signed the agreement, the husband filed a motion with the court which referenced his alleged acceptance of the agreement. The husband argued that, although he signed after the deadline, his acceptance was still valid and that therefore the terms of the agreement should be integrated into the final divorce decree. The wife argued that the husband’s failure to sign in a timely manner rendered the signed agreement unenforceable. The husband initially lost at the trial court level and then appealed.

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Ruling & Post-Ruling Discussion

The appellate division ultimately ruled against the husband. Again, as mentioned earlier, Maryland courts will apply principles taken from basic contract law when they examine certain issues with marital settlement agreements. In this situation, the issue presented by the case is referred to as a “condition precedent” in legal-contractual parlance. Essentially, the wife made acceptance of the agreement by a certain time a condition of the acceptance. This is similar to how other contracts work in the commercial world, such as offers for goods at a specific price which expire after a certain time. Applying basic contract principles, the appellate division stated that the husband’s late acceptance was the same as acceptance of an offer which had been revoked; in other words, when the deadline for acceptance passed, this was the same as the wife formally revoking the offer, which means that the husband lost the option of signing at a future point. This is a key lesson for litigants which may be in this position at some point in the future.

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Contact the Murphy Law Firm for Additional Information

If you would like to learn more about marital settlement agreements, acceptance deadlines, contract law as applied to settlement agreements, or another related issue, contact one of the family law attorneys at the Murphy Law Firm by calling 240-219-8963.

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