Coleman v. Coleman

TAMILIA, Judge,

dissenting:

I dissent and would view this conflicts of law situation in the following fashion.

When the Pennsylvania divorce is filed prior in time to the foreign proceeding and both parties are Pennsylvania domiciliaries, there are a number of options available to the local petitioner. An injunction against proceeding may be requested against the respondent to prevent out-of-state action.1 Upon failure to comply, the court may impose sanctions, issue protective Orders as to the property, and ultimately treat the Nevada divorce as a nullity as to its effect on property and proceed to equitable distribution.

If the Nevada divorce was filed first in time (as here), and/or there is participation actively in the Nevada divorce by the respondent, jurisdiction is acquired by the Nevada Court over the marriage status and it is in that court that the issues must be resolved. Coe v. Coe, 334 U.S. 378, 68 S.Ct. 1094, 92 L.Ed. 1451 (1948); Sherrer v. Sherrer, 334 U.S. 343, 68 S.Ct. 1087, 92 L.Ed. 1429 (1948). Pennsylvania *464equitable distribution depends on the marital status existing at the time a claim is made for equitable distribution. The Pennsylvania Court has no jurisdiction to enter a divorce decree, or any remedies ancillary thereto, if it has already been entered in a foreign jurisdiction. Perrin v. Perrin, 408 F.2d 107 (3rd Cir.1969). The Divorce Code, 23 P.S. § 301 Jurisdiction, permits determination of certain property matters (equitable distribution) and alimony only in cases where it has jurisdiction to grant the divorce. While a divorce may be granted prior to a decree of distribution, through bifurcation, no claim for equitable distribution can be made after a decree of divorce is final. 23 P.S. § 401(j); Bastion v. Bastion, 324 Pa.Super. 569, 472 A.2d 226 (1984). After a divorce decree is entered, the only recourse is partition. Once the foreign divorce decree is recognized or a domestic decree is entered, the power over property for equitable distribution purposes is gone. Bastion, supra. Neither the Nevada courts or the parties by agreement can preserve that power or impose upon the court the duty to hear those matters.

In the situation in which the foreign divorce action is ex parte, the Pennsylvania respondent admittedly has few options. The alternatives to contesting the Nevada divorce are: do nothing and contest validity of the divorce in Pennsylvania, and if successful, thereafter pursue a Pennsylvania divorce and equitable distribution; contest the Nevada divorce on jurisdictional grounds only, in Nevada, or in federal courts on the basis of diversity, preserving the right to proceed in Pennsylvania on the merits. Williams v. North Carolina (II), 325 U.S. 226, 65 S.Ct. 1092, 89 L.Ed. 1577 (1945).

The majority would permit participation in the Nevada divorce and would consider it to have the same effect that would reasonably follow if appellant had been first in time in filing in Pennsylvania, followed by suitable sanctions to protect her interest, or had not participated in the Nevada action but successfully contested jurisdiction of the Nevada Court and the validity of the Nevada Decree. Appellant *465may elect one or the other approach, but having done neither and having elected to participate actively on the merits in Nevada proceeding, she loses any benefit that might have been derived.

The legislative intent is clear in providing for the alternative nature of equitable distribution. It provides, additionally, for an alternative evaluation of property as matrimonial property only for the purpose of division pursuant to a divorce action.

23 P.S. § 401(d)
(d) In a proceeding for divorce or annulment, the court shall, upon request of either party, equitably divide----
(e) For purposes of this chapter only, “marital property” means....

If it had intended to preserve equitable distribution on foreign decrees (which would be a contradiction in terms as distribution may not be claimed after a decree of divorce is entered, Bastion, supra), it would have provided a remedy precisely as is the case for alimony. See 23 P.S. § 505 Alimony where a foreign ex parte divorce or annulment. Even with alimony, it is made explicitly clear that the foreign decree must be ex parte. Where the divorce is participatory, all states having the power to make alimony awards, the court selected by the parties to hear the divorce is empowered and should be requested to enter an alimony decree. Such a decree is enforceable in Pennsylvania pursuant to section 506 Enforcement of foreign decrees, or pursuant to RURESA, 42 Pa.C.S.A. § 6776. There is no recourse for a participatory divorce, where the foreign court failed to enter an alimony Order, and as to property, the remedies available are those existing without reference to section 401(d). The doctrine of divisable divorce is applicable only to the extent that remedies are available in the state of domicile, see Stambaugh v. Stambaugh, 458 Pa. 147, 329 A.2d 483 (1974) (any change in Pennsylvania divorce law, with respect to provisions for alimony following *466divorce from bond of matrimony, must be made by the legislature), and protects primarily a party victimized by an ex parte divorce. See Sohmers, infra. To permit otherwise would be an invitation to fragment divorce and domestic relations proceedings interminably producing hardship to the parties and confusion in the courts.

The reasons are clear. In Gantz v. Gantz, 338 Pa.Super. 528, 488 A.2d 17 (1985), we held our legislature has determined that where a divorce is pursued, all matters to be considered should be heard in the same court, and whenever possible, by the same judge or master. This rule is no different for an out-of-state divorce than for a domestic divorce. As to conflicts of laws, admittedly the best state (or county) to determine the issue concerning division of property is the one where the property is situated. This is not, however, an overwhelming impediment as the state where the divorce is sought should be able to apply the law of the state where the property is located. If the parties are willing to trust their marriage dissolution to a court other than the home state, which is the state of paramount interest, how can they be heard to complain of its power and ability to resolve property issues in that forum. Forum shopping is not new, intra-state as well as interstate; to diminish it and control it, the law and rules concerning domestic relations actions must be construed so that they are not rendered impotent. To- eliminate the abominations of forum shopping and child snatching that arose in custody actions, the Commission on Uniform Laws promulgated, and most states have joined in, the Uniform Child Custody Jurisdiction Act, 42 Pa.C.S.A. § 5341 et seq. While nothing similar has developed in the law of divorce (except intrastate, see Gantz, supra), we have lessened the problem in support cases with the Revised Uniform Reciprocal Enforcement of Support Act (RURESA) (1968) 23 Pa.C.S.A. § 4501 et seq., and in alimony by universal application of sections such as 23 P.S. § 505 Alimony where a foreign ex parte divorce or annulment, and permitted registration of foreign alimony Orders. Sohmer v. Sohmer, 318 Pa.Super. 500, 465 A.2d 665 (1983) correctly applied the law in its disposi*467tion of an alimony claim arising out of a participatory divorce in Virginia by denying the right to proceed in Pennsylvania, after the decree by the Virginia court. Cheng v. Cheng, 347 Pa.Super. 515, 500 A.2d 1175 (1985) distinguished Sohmers by permitting determination of equitable distribution claims because the property was located in Pennsylvania (support and alimony are in personam actions). Cheng is distinguished from Coleman in that there was a prior existing divorce action, coupled with a stipulation from the South Carolina action, preserving the right to proceed with equitable distribution in Pennsylvania. The jurisdiction of the Pennsylvania Court was not ousted, at least initially; however, a South Carolina divorce decree terminated the court’s power to act in granting a divorce as effectively as if it had been a local decree. Williams v. North Carolina (I), 317 U.S. 287, 63 S.Ct. 207, 87 L.Ed. 279 (1942). The decree was entered on April 20, 1982, whereas the hearing in Pennsylvania on the economic issues did not occur until April 13, 1983. There is no question of the husband’s status as a South Carolina domiciliary as he had been there almost two years (located there July 1980) before entry of the decree. The South Carolina decree is unassailable. Under the Divorce Code, separation of the divorce and property matters can only be accomplished through a court Order of bifurcation. See 23 P.S. § 401(b); 42 Pa.R.C.P. 1920.52(c); Pastuszek v. Pastuszek, 346 Pa.Super. 416, 499 A.2d 1069 (1985); Wolk v. Wolk, 318 Pa.Super. 311, 464 A.2d 1359 (1983). This did not occur in either Cheng or Coleman. This may have been inadequate in either case, where the divorce action was already filed in the foreign jurisdiction. If there had been a proper Order of bifurcation, preceded by the mandatory hearing, after a valid complaint in divorce had been filed, first in time, a good argument could be made that a subsequent foreign divorce decree did not prevent equitable distribution. However, as here, stipulation of the parties cannot confer that jurisdiction, when the only entry is pursuant to a complaint in divorce before the instant court, followed by a foreign divorce decree which incorporates a decree of distribution.

*468The Nevada decree entered on May 9, 1984, in pertinent part, is as follows:

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the existing Support Order in the Court of Common Pleas of Northampton County, Pennsylvania, relative to the support of the minor daughter, Heidi Coleman, be and the same is hereby affirmed and adopted by this Court;
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Plaintiff shall transfer and convey by appropriate deed to the Defendant all his right, title and interest in and to the marital home located in the State of Pennsylvania thereby vesting the property in the name of the Defendant as her sole and separate property absolutely;
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Plaintiff shall pay to the Defendant the sum of $25,000.00 in lieu of Nevada alimony, and without prejudice to the Defendant’s right to pursue any relief in the State of Pennsylvania relative to such matters and/or property within the jurisdiction of the Pennsylvania Domestic Relations Court; ____

The Nevada Court did consider property issues and alimony and entered a decree to that effect. No rationale can justify failure to resolve any and all property and alimony matters therein. At least in Cheng there was a Pennsylvania divorce pending, and reservation by the foreign court of all property matters to be decided by the Pennsylvania Court.

In Coleman, there is no Pennsylvania divorce action and the only legal vehicle possible does not exist for purposes of entering such a decree.

Without the limited, explicit and unalterable proceedings detailed in the Divorce Code for equitable distribution of marital property, no legal means exists for such a distribution. The majority weaves an extensive legal stratagem for creating power in the court to decree equitable distribution *469and alimony, when the legislature failed to grant that power. This, we may not do.

In this case, Mrs. Coleman would have been better off not to have gone to Nevada, but to have contested Nevada’s jurisdiction in Pennsylvania under Williams v. North Carolina (II), supra. It appears Mr. Coleman is still here and has never acquired a bonifide Nevada domicile. This approach is given improved chances of success with recent United States Supreme Court rulings restricting long arm statutes and ex parte proceedings in foreign jurisdictions when minimum contracts have not been established. See Shaffer v. Heitner, 433 U.S. 186, 97 S.Ct. 2569, 53 L.Ed.2d 683 (1977).2 Also with what amounts to a national divorce property and alimony policy, no fault grounds being universally available, the relaxed approach to migratory divorce should now come under closer scrutiny. Mr. Coleman now has a valid divorce because of Mrs. Coleman’s participation. Mrs. Coleman’s position would have been stronger if she had initiated a Pennsylvania divorce before Mr. Coleman had initiated the Nevada divorce (including requests for injunctions, etc.) and if she had requested bifurcation, and whatever else necessary to preserve her right to pursue equitable distribution and alimony. Having failed that, she has been relegated to an action in partition pursuant to the Act of May 10, 1927, P.L. 884, § 1, 68 P.S. § 501 which converts a tenancy by the entireties into a tenancy in common of equal one-half shares after a divorce and permits either party to partition the property.

Likewise, had this been an ex parte divorce, a partial salvation of her position would have been achieved by proceeding for alimony under 23 P.S. § 505,3 which permits *470filing for alimony in Pennsylvania when a foreign ex parte divorce granted in a sister state is in need. All of the relevant factors contained in 23 P.S. § 501 are to be considered and if the distribution of marital property was uneven and the wife’s contribution was not adequately compensated, the alimony award could reflect this. It is not a substitute, however, for equitable distribution.

Underlying our entire discussion is the coherent and interelated structure of the Divorce Code and domestic relations law ih general. The Divorce Code does not abrogate existing laws when there is no conflict and provides in section 103, Construction: “The provisions of this act, so far as they are the same as those of existing laws, are intended as a continuation of such laws____”

The existing law as to distribution of marital property is partition which comes into operation after a decree of divorce is entered. Section 508, supra. See Marinello v. Marinello, 354 Pa.Super. 471, 512 A.2d 635 (1986). Only when a divorce action has been filed, and a claim made for equitable distribution, followed by a hearing and determination prior to divorce (except when proper bifurcation was ordered), can section 401, permitting equitable distribution, apply. Cheng reaches for the right result but skirts the problem since there had been no Order of bifurcation severing the Pennsylvania divorce action from the alimony and distribution claims. It would be procedurally tenable for a divorce action to be instituted in Pennsylvania coupled with a claim for equitable distribution and alimony, to preserve those claims by Order of bifurcation and thereafter treat *471the divorce, even if acquired in a foreign jurisdiction,’' to have no bearing on the authority of this Court to resolve the collateral matters. To permit alimony and property matters to be disposed of after a valid decree in divorce, without bifurcation, destroys the integrity of the law which has been codified in the divorce statute and laboriously refined by case law. See Bastion, supra.

Stipulation (or savings clauses in a foreign divorce decree) cannot substitute for an Order of bifurcation. If such is permissible in foreign divorce cases, which are frequently suspect on their facts and findings, how much more appropriate would it not be in a domestic divorce action. Parties cannot stipulate between themselves to impose jurisdiction on the court, nor can their stipulation substitute for the hearing and bifurcation determination by the court. Pas-tuszek, supra. The entire process, including the discretion to be exercised by the court, would be supplemented by the stipulation. The only exception in the Divorce Code, to the required proceeding (complaint in divorce, claim for alimony and equitable distribution, Order of bifurcation, decree) is an agreement by the parties on the division of property and/or alimony (section 401(e)(2)), which the court may then adopt and incorporate in the decree. Hollman v. Hollman, 347 Pa.Super. 289, 500 A.2d 837 (1985); Tokach v. Tokach, 326 Pa.Super. 359, 474 A.2d 41 (1984).

In contrast to the majority view, which would appear to attain a just result, albeit by impermissible means, my view would appear to be harsh. However, never has the addage, bad cases make bad law, been more appropriate.

The approach espoused by the majority confuses the laws of judgment, jurisdiction and procedure and makes exceptions for foreign decrees and procedures which would not be permitted for domestic cases. It encourages migratory divorce because of the confusion engendered. A local domiciliary should not be able to escape the consequence of Pennsylvania law by stepping across a state line, and he and his decree should not be accorded legality simply because he does so. Williams v. North Carolina II, supra. *472Conversely, two domiciliarles should not be permitted to submit themselves to a foreign jurisdiction and then call upon Pennsylvania courts to contest that jurisdiction’s law and procedures or permit the foreign court to alter Pennsylvania law and procedures in order to accommodate a party who is dissatisfied with the results of a foreign procedure. Pennsylvania law does not deny the parties their day in court, it simply restricts remedies available. Partition is available, equitable distribution is not; alimony is available if claimed in Nevada but not if the decree doesn’t provide for it.

While section 401(c), which provides:

(c) In all matrimonial causes, the court shall have full equity power and jurisdiction and may issue injunctions or other orders which are necessary to protect the interests of the parties or to effectuate the purposes of this act, and may grant such other relief or remedy as equity and justice require against either party or against any third person over whom the court has jurisdiction and who is involved in or concerned with the disposition of the cause.

would seem to apply, it can come into play only if the court has jurisdiction. When the case was properly before the court, it provided extensive remedies and recourse for the appellant. Once the decree was entered in Nevada, the remedies were restricted to partition and registration of the Nevada alimony decree pursuant to RURESA, 42 Pa.C.S.A. § 6776-6780 or 23 Pa.S.A. § 506, having to do with registration and enforcement of foreign support Orders.

Sohmers started on a straight course, Coleman would place us on a forty-five (45) degree tangent. If we would follow the law and apply the procedures so clearly mandated by the Divorce Code, in due time with the proper instructions to the bar and the courts, most of the difficulties would resolve themselves. To follow the approach outlined by the majority creates a morass of judge-made law and confusion in application of statutory law. If a different approach is needed, it should be left to the legisla*473ture or more likely to the Commission on Uniform Laws. I would affirm the Order of the lower court.

POPOVICH, J., joins in this dissenting opinion.

. This is assuming, of course, that the husband was not an out-of-state domiciliary since anti-suit injunctions may not properly issue where it has been established that the enjoined spouse is a domiciliary of another state. Stambaugh v. Stambaugh, 458 Pa. 147, 329 A.2d 483 (1974); Smith v. Smith, 364 Pa. 1, 70 A.2d 630 (1950).

. E. Roy Hawkins, The Effect of Shaffer v. Heitner on the Jurisdictional Standard in Ex Parte Divorces, Family Law Quarterly, Volume XVIII, no. 3, Fall 1984, p. 311.

. § 505. Alimony where a foreign ex parte divorce or annulment

Whenever a person who was a resident of this Commonwealth at the time such person was a defendant or respondent in a foreign ex parte action for annulment or divorce petitions a court of this Commonwealth for alimony and establishes the need therefor, such *470court, if it has jurisdiction over the person or property of the other party, may order that such alimony be paid in the same manner and under' the same conditions and limitations which pertain when alimony is sought as provided in this chapter. In the event that the other party from whom such alimony is sought cannot be located within this Commonwealth, the court may attach such of the tangible or intangible property of said party as is within the jurisdiction of the court in the manner provided by the Rules of Civil Procedure, except that no exemption shall apply. Such property shall thereupon be subject to the payment of alimony in the same manner as provided by law in actions for nonsupport. 1980, April 2, P.L. 63, No. 26, § 505, effective in 90 days.