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Arizona Court of Appeals - 135 Ariz. 346
Tags: Contracts, Quasi-contract, Restit
tl;dr:
Wife put off her plans for graduate school as part of an agreement with her husband, where she would work while he attended law school, and then he would support her afterward. But the husband then asked for a divorce before the wife went to grad school.Video Summary
Case Summary
In the 1982 case Pyeatte v. Pyeatte, the Arizona Court of Appeals dealt with the enforcement of a promise between spouses during a divorce. The husband had promised to support his wife while she got her master's degree, and in return, she supported him while he obtained his law degree. After the husband graduated and became a lawyer, he divorced his wife. She then sued for breach of contract and unjust enrichment.
The trial court determined that this promise wasn't an enforceable contract but awarded the wife $23,000 for unjust enrichment. The husband appealed, and the Court of Appeals agreed with the trial court. The court explained that the promise lacked specific terms—like timeframe, location, and compensation—and didn't have enough consideration since it was based on past duties.
However, the court held that the wife deserved restitution for unjust enrichment because she financially supported her husband's education with the understanding that he'd reciprocate after he became a lawyer. It would be unfair to let the husband benefit without compensating his wife.
This case is significant because it clarified the legal principles involved in enforcing promises between spouses during a divorce. It also showed that courts assess a promise's clarity and fairness when deciding whether it's enforceable or not. This case remains an authoritative source on the topic.
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The court upheld an award of $23,000 to the wife in a dissolution decree due to the husband's breach of an oral agreement to provide sole support for the marriage while the wife obtained further education. However, the court ruled that the agreement was unenforceable as a binding contract due to the absence of essential terms. The wife may be entitled to restitution in quantum meruit to prevent the husband's unjust enrichment, as he received his education at her expense. The court rejected the wife's claim for reimbursement of her husband's legal education, stating that education cannot be considered property subject to division. The court is considering whether restitution based on unjust enrichment is appropriate in a marital relationship, and recognizes that a community estate can be consumed by a spouse's education, which was largely supported by the other spouse's efforts and sacrifices. While a degree is not considered property subject to division, equitable relief may still be granted. The equities favor providing a remedy to the working spouse in cases where one spouse sacrifices their earned income to support the other spouse's pursuit of an advanced education, with the expectation of enjoying a higher standard of living in the future.
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