Estate of Anello v. McQueen

DAVIS, Associate Presiding Judge

(dissenting):

I write in dissent to part II of the majority opinion. In particular, I believe the majority mistakenly interprets the specificity required by Culbertson v. Continental Assurance Co., 631 P.2d 906 (Utah 1981), to divest a former spouse of a mere expectancy interest.

In Culbertson, the court expressed the rule that “general expressions or clauses in [property settlement] agreements [and divorce decrees] are not to be construed as including an assignment or renunciation of expectancies.” Id. at 910. The Culbertson court then conducted a thorough analysis of the case law pertaining to the renunciation of expectancies in divorce decrees. In so doing, the court concluded that three categories of expectancy renunciation cases exist:

In the first, the spouse, in the property settlement or decree of divorce, relinquishes any claim to ownership of the policies and frequently agrees to execute any documents to sever such interest. Unless there is in addition a specific provision in the decree or property settlement explicitly waiving the expectancy interest the former spouse is entitled to receive the proceeds as designated beneficiary.... In the second group of cases, the insurance policy is not specifically mentioned in the property settlement or decree of divorce, however, there are provisions effecting a complete settlement of the parties’ property interests and awarding each all right, title, and interest to his respective property. An agreement with such general provisions is deemed merely to effect a division of the parties’ property, and the courts rule they cannot reasonably infer from such language that the spouse has released an expectancy interest as the beneficiary under his former spouse’s insurance policy. In the third group of cases, *1034the language in the property settlement or decree of divorce was sufficiently comprehensive as to establish clearly that the spouse had waived or relinquished any expectancy.

Id. at 912-13 (footnotes omitted) (emphasis added). I believe the documents here at issue fall squarely -within the third category.

Pursuant to the parties’ settlement agreement, which specifically states, “[decedent] has an Individual Retirement Account in the approximate amount of $58,000”, appellant clearly “relinquished] all claim to th[e] account.” (Emphasis added.) Additionally, the parties’ decree of divorce states, “[appellant] and [decedent] are awarded their own separate IRA[s], as their individual and separate property, free and clear of any claim or interest of the other party.” (Emphasis added.) In the settlement agreement, decedent’s IRA was specifically identified and appellant, intending the agreement “to be the full, complete and final adjustment of any and all property rights ... existing as of the date of this agreement”, relinquished any claim she may otherwise have had to the referenced account. Similarly, by the explicit terms of the parties’ divorce decree, decedent was awarded his IRA “free and clear of any claim or interest of the other party.” (Emphasis added.) This decree, by use of the term “any” in relation to “claim or interest” held by appellant, as well as specifically referencing decedent’s “own separate IRA”, and having more specifically identified the IRA in the Property Settlement Agreement, is “sufficiently comprehensive as to establish clearly that the spouse had waived or relinquished any expectancy.” Id. at 913.

Thus, this case does not fall within the first category set out in Culbertson, because the settlement agreement and the divorce decree both relinquish more than “any claim to ownership”, but also relinquish any interests and/or claims to decedent’s specifically identified IRA account, which necessarily include the expectancy interest and/or claim at issue here. This case obviously does not fall into the second Culbertson category because here decedent’s IRA was specifically mentioned and addressed, along with several other specific insurance and retirement funds, among the enumerated list within the divorce decree. Hence, only the third Culbertson category remains, into which the facts of this case clearly fall.

Since, as a matter of law, appellant explicitly waived any expectancy she may otherwise have had to decedent’s IRA, it is unnecessary to reach the issue of decedent’s intent addressed in part I of the majority’s opinion. I would affirm the trial court’s order granting summary judgment in favor of the personal representative of decedent’s estate.