Marriage of Mahoney v. Mahoney

LANSING, Judge,

dissenting.

Glenna Mahoney’s section 548.14 action is equitable in nature and governed by equitable principles. Bloomquist v. Thomas, 215 Minn. 35, 42, 9 N.W.2d 337, 341 (1943). Although Gene Mahoney’s actions may not constitute the degree of fraud for which relief is typically granted, Minnesota's interest in providing its residents with fair and reasonable maintenance awards requires us to exercise our inherent equitable powers and to vacate the dissolution decree.

Gene Mahoney, who is 65, is a retired civil service employee periodically employed as a consultant for a defense subcontractor. Glenna Mahoney, who is 68, is retired and receives a small social security pension. After their marriage in 1949, Glenna Mahoney worked to support Gene Mahoney until he received a civil engineering degree and obtained a job with the Army Corps of Engineers. During their marriage, she received treatment for serious health problems and mental illness. The couple separated in 1977, and Glenna Mahoney moved to Minnesota.

*235In 1986 Glenna Mahoney filed for divorce in Alabama, where Gene Mahoney continued to reside, but agreed to amend her petition to request a divorce a mensa et thoro. The Alabama court granted the petition, ordering Gene Mahoney to make monthly support payments of $500. The court also divided the parties’ property so that Glenna Mahoney received $10,000; fifty-five percent of Gene Mahoney’s civil service retirement survivor’s annuity; and continued coverage under his medical insurance.

A few months later, the parties independently attempted to effect a complete divorce. Because Alabama requires a two-year waiting period before a divorce a mensa et thoro may be converted to a divorce a vinculo matrimonii, each petitioned in another forum. Gene Mahoney fraudulently obtained a dissolution in Nevada and terminated Glenna Mahoney’s coverage under his medical insurance. Glenna Mahoney, unaware of the Nevada divorce decree, petitioned for dissolution in Minnesota, where she had resided for 13 years.

The Minnesota court granted her petition for divorce but because it lacked personal jurisdiction over Gene Mahoney, was unable to address spousal maintenance. On appeal to this court, see Mahoney v. Mahoney, 433 N.W.2d 115 (Minn.App.1988), pet. for rev. denied (Minn. Feb. 10, 1989), Gene Mahoney argued that Minnesota could not make a maintenance determination because the Alabama judgment obligating him to pay monthly support was entitled to full faith and credit.

He then brought an action in Alabama to extinguish his support obligations. Alabama, which refuses to recognize the doctrine of divisible divorce, concluded that Gene Mahoney’s support obligations were terminated by the Minnesota dissolution and that Glenna Mahoney was precluded from seeking maintenance in Alabama.

Although Glenna Mahoney’s inability to receive maintenance is primarily attributable to the harsh effect of Alabama’s marital dissolution laws — which forced her to either wait two years before petitioning for a complete divorce in Alabama or to sacrifice her right to maintenance by petitioning in a foreign jurisdiction — we cannot ignore this state’s contribution to the result. By granting the partial relief of dissolution, we inadvertently eliminated her right to obtain full relief, which necessarily includes an award of maintenance and possibly a reexamination of the allocation of Gene Mahoney’s pension rights.

Recognizing the state’s interest in section 548.14 actions involving marital dissolution, see Bloomquist, 215 Minn. at 43, 9 N.W.2d at 342, we cannot condone the unconscionable result created by the extraordinary circumstances of this case. The court, acting on behalf of the citizens of the state, has a duty to protect the interests of state residents and to ensure that the results of a marital dissolution are fair and reasonable. See Karon v. Karon, 435 N.W.2d 501, 503 (Minn.1989). Accordingly, under the unique and unforeseeable circumstances of this case, equity requires this court to vacate the Minnesota divorce decree.