McKeown v. McKeown

DEL SOLE, Judge,

dissenting.

I respectfully dissent from the majority’s opinion. Although I agree that our case law distinguishes between spousal support and alimony pendente lite, and that conversion from support to alimony pendente lite is not automatic, I disagree with the majority’s conclusion that because Wife failed to apply for alimony pendente lite, the trial court never had the opportunity to determine whether Wife was entitled to this award. Rather, I believe that under the facts of this case, the trial court did determine that Wife was entitled to alimony pendente lite in the amount of $100.00 per week because the circumstances of the parties had not changed. Furthermore, I would hold that our case law supports the trial court’s actions in retroactively converting spousal support to alimony pendente lite despite the failure of the dependent spouse to file an application for alimony pendente lite.

In Purdue v. Purdue, 398 Pa.Super 228, 580 A.2d 1146 (1990), a support order was entered requiring Husband to pay support for his wife and minor child. Then the parties were divorced in a bifurcated divorce action, and years later the trial court, in considering the economic claims for equitable distribution, entertained Husband’s claim that his support award should be reduced retroactive to the time of wife’s remarriage. Husband was not notified of Wife’s *525remarriage at the time it occurred. The trial court refused to credit Husband in the equitable distribution award with the amount of support payments retroactive to the time of Wife’s remarriage, commenting that support awards automatically convert to alimony pendente lite at the issuance of a divorce decree, and alimony pendente lite does not necessarily terminate because of a party’s remarriage. DeMasi v. DeMasi, 366 Pa.Super. 19, 530 A.2d 871 (1987).

This court reversed the trial court, holding in accordance with Levine v. Levine, 360 Pa.Super. 297, 520 A.2d 466 (1990), that spousal support does not automatically convert to alimony pendente lite, and remanding to the trial court for a determination of whether Wife was entitled to an award of alimony pendente lite following the divorce. We held:

[b]ecause in this case we are uncertain whether the court meant for wife to receive alimony pendente lite following the divorce, and because the effect of remarriage and husband’s claim of lack of knowledge concerning the remarriage were not examined by the trial court, we conclude that a remand is in order.

Thus, we held in Purdue that the trial court may not assume that spousal support continues under a different name as alimony pendente after a divorce has been entered and prior to consideration of the economic claims of the parties, without determining the spouse’s entitlement to alimony pendente lite and the amount of that entitlement. We did not hold, however, that the trial court is precluded from deciding retroactively that the spouse was entitled to alimony pendente lite after the divorce is entered, rather we remanded so that the trial court could make its determination.

Similarly in Krakovsky v. Krakovsky, 400 Pa.Super. 260, 583 A.2d 485 (1990), we vacated ah order of equitable distribution when the trial court erroneously used a modified support order to serve three separate purposes, spousal support, alimony pendente lite, and arrearages on the modified support order as replacement for an alimony award. *526We stated that spousal support arises from the marital relationship and is designed to assure a reasonable living allowance to the dependent spouse, while alimony pendente lite is awarded to sustain the dependent spouse on a basis of equality with the other spouse while maintaining or defending the divorce action. Id., 400 Pa.Super. at 266-267, 583 A.2d 485. However, we then remanded to the trial court for it's “ultimate decision on the issues of alimony pendente lite and alimony”, Id., 400 Pa.Super at 269, 583 A.2d 485. Therefore, the trial court was not precluded from retroactively changing the award of support into an award of alimony pendente lite if the trial court determined the party was eligible for alimony pendente lite in the amount ordered. We remanded for the trial court to make this decision although the dependent spouse did not apply to the court for alimony pendente lite at the time of the final decree in divorce.

Our concern in both these cases was that the trial court consider the discrete purposes for spousal support and alimony pendente lite, and recognize that the circumstances of parties are subject to change throughout each of the steps of the dissolution of a marriage and accompanying property settlement. Id., 400 Pa.Super. at 267-268, 583 A.2d 485.

In the instant case, I would find that the trial court in dismissing the petition to terminate spousal support, and, in effect, retroactively changing it to alimony pendente lite, addressed the concerns we raised in Krakovsky and Purdue. Here, the divorce decree and the equitable distribution order were simultaneous, but because Husband appealed only from the order of distribution, the divorce became effective although no distribution took place.1 Therefore, *527throughout these stages of the dissolution of the marriage, the circumstances of the parties remained the same. The court, in dismissing Appellant’s petition to terminate spousal support, and stating that spousal support and alimony pendente lite are indistinguishable when Husband did not comply with the prior equitable distribution order of the court, recognized that the circumstances of the parties had not changed because of the divorce decree. In order to sustain the dependent spouse on a basis of equality with the other spouse while litigating the divorce action, Id,, 400 Pa.Super at 267, 583 A.2d 485, it was necessary to maintain the status quo by maintaining the order in the same amount.

23 Pa.C.S.A. § 3323(f) states in pertinent part that, “[i]n all matrimonial causes, the court shall have full equity power and jurisdiction ... to effectuate the purpose of this part and may grant such other relief or remedy as equity and justice require against either party ...” We held in Cheng v. Cheng, 347 Pa.Super. 515, 500 A.2d 1175 (1985), that one of the purposes of this “part”, or one of the policies of the Divorce Code, is to, “[ejffectuate economic justice between parties who are divorced ... and insure a fair and just determination of their property rights.” 23 Pa.C.S.A. § 3102(a)(6).

I would find that the trial court’s action in dismissing Husband’s petition to terminate spousal support fulfills the policies of the Code, and did not constitute an abuse of discretion. Remick v. Remick, 310 Pa.Super. 23, 456 A.2d 163 (1983).

. Here, distribution should have occurred after the order of equitable distribution was filed because Husband failed to file a supersedeas and post bond staying the enforcement of the order. However, because wife did not seek enforcement of the order prior to the time this court issued a memorandum opinion vacating the order, we find that the original order of distribution is unenforceable.

*527However, it should be noted that the situation we face here would be the same had Husband filed a supersedeas, because in both cases distribution would not have occurred, and would have to be postponed until a new distribution order was fashioned by the trial court.