Marriage of Plonske v. Plonske

OPINION

NORTON, Judge.

The parties’ marriage of ten years was dissolved by judgment and decree entered on December 10, 1990. All matters of the dissolution were settled by stipulation of the parties except one issue: whether to include a provision providing that the cohabitation by appellant Brenda F. Plonske with an unrelated male for a continuous period of more than 30 days would trigger a mandatory redemption of respondent Edward F. Plonske’s interest in the homestead property. The trial court included the disputed provision in the final judgment and decree. This appeal is taken from the judgment. We reverse and remand to the trial court to strike the disputed provision from the judgment and decree.

FACTS

The parties were married on December 6, 1980. There was one minor child born of the marriage, Elizabeth Mary Plonske, age 9. Appellant also has a minor son from a previous marriage. The parties have permanent joint legal custody of Elizabeth and appellant has primary physical custody of Elizabeth. Respondent is obligated to pay child support for Elizabeth in the amount of $475 per month and spousal maintenance of $100 per month. The maintenance obligation will cease after 36 months.

*912The parties owned a homestead in joint tenancy with a joint mortgage. Pursuant to stipulation, appellant was given all right, title, interest, and equity in and to the homestead, subject to an interest free lien in favor of respondent for one-half of the net equity of the homestead. Appellant is solely responsible for all payments, principal, interest, taxes, and insurance on the homestead.

The parties stipulated to the terms of the judgment and decree except for one matter, which is the subject of this appeal. The parties disagreed over the inclusion of paragraph 8(b)(4) in the judgment and decree. Paragraph 8(b)(l)-(4) provides the following:

(b) The house shall be offered for sale and sold and Respondent’s lien satisfied upon the earlier of:
1) The minor child graduates from high school or is otherwise emancipated or dies;
2) [Appellant’s] remarriage;
3) Any refinancing, by [appellant];
4) The continuous cohabitation by [appellant] for a period of more than SO days with an unrelated male adult in the homestead.
Upon the occurrence of one of the above events, the house shall be placed on the market for sale at fair market value within 60 days. Respondent shall select a realtor from a locally prominent established realty firm to market the homestead.

(Emphasis added). Paragraph 8(c) of the judgment and decree provides that upon the occurrence of one of these triggering events, appellant will have the option of buying out respondent’s interest in lieu of placing the house on the market.

Rather than go to trial, the parties agreed to present two versions of the Findings of Fact, Conclusions of Law, Order for Judgment, and Judgment and Decree to the trial court, one including the disputed provision and one without it, together with letter briefs to the trial court supporting their respective positions. The trial court included the disputed paragraph 8(b)(4) in the final judgment and decree. This appeal is taken from the judgment.

Appellant challenges the inclusion of the cohabitation provision, paragraph 8(b)(4), which was not stipulated to in the final judgment and decree. She does not challenge the inclusion of the three other provisions, as contained in paragraph 8(b)(l)-(3), as these were stipulated to by the parties.

ISSUE

Did the trial court err by including in the final judgment and decree a provision, absent stipulation by the parties, which requires appellant to either sell the homestead or buy out respondent’s interest therein so as to satisfy respondent’s lien on the homestead if she cohabitates with an unrelated male for more than thirty days?

ANALYSIS

This is an appeal directly from the final judgment and decree of dissolution, challenging a provision contained therein that involves occupancy of the homestead. Although this case does not involve modification of occupancy of the homestead, an analysis of the law that applies in modification cases is instructive in showing the development of the law and supports our conclusion that the inclusion of the challenged provision, paragraph 8(b)(4), is an error of law.

Absent stipulation to the contrary, modification of the right to occupancy of the homestead, like modification of maintenance and child support, “should be allowed only when the party seeking modification can show a material change in circumstances.” Angelos v. Angelos, 372 N.W.2d 405, 407-08 (Minn.App.1985) (emphasis added) (former husband’s remar riage did not constitute “a sufficient change in circumstances to require modification of the occupancy of the homestead” awarded to him by stipulation where stipulated decree specifically provided that person he remarries acquires no property rights in the homestead but failed to provide that remarriage would trigger a forced sale of the homestead), pet. for rev. denied (Minn. Oct. 24, 1985).

*913In Saabye v. Saabye, 373 N.W.2d 386 (Minn.App.1985), the wife was awarded occupancy of the homestead. The parties stipulated that the husband’s lien on the homestead was payable upon the sale of the property or upon the wife’s remarriage. The parties considered but rejected the idea of also including in their stipulation cohabitation by the wife as a triggering event. The house was to be sold when the two minor children, one of whom lived in the home with the wife, were emancipated. Shortly after the dissolution a male moved into the homestead with the wife and contributed to the household expenses. Id. at 387.

The court first held that the language of the judgment postponing the payment of the lien was in the nature of child support because its purpose was to accommodate occupancy of the homestead by minor children of the marriage. As such, it was subject to modification upon a showing of a change in circumstances. Id.; see also Kerr v. Kerr, 309 Minn. 124, 243 N.W.2d 313, 315 (1976) (where, pursuant to stipulation, wife was awarded homestead subject to lien in favor of husband payable upon sale, wife’s death, or emancipation of youngest child, the decree operated to encourage occupancy of the homestead by the parties’ minor children and, in effect, was security for payment of child support. As such, the occupancy of the homestead provision was subject to modification); Thomas v. Thomas, 356 N.W.2d 76, 78 (Minn.App.1984) (postponement of husband’s real ization of proceeds secured by lien on homestead occupied by wife until her death or remarriage operated to encourage occupancy of the homestead by the minor children and was security for payment of child support. The postponement provision is in the nature of child support and therefore can be modified only upon a showing of material change in circumstances).

In Saabye, after deciding the occupancy of the homestead was subject to modification, the court held that the cohabitation by the wife, absent a stipulated provision, was not a sufficient change in circumstances to trigger the satisfaction of the husband’s lien on the homestead. Saabye, 373 N.W.2d at 387. The court explained that the fact the wife occupying the homestead received financial contributions to the household from the man cohabitating with her was a circumstance normally found in situations of remarriage or cohabitation. Therefore, the court found a holding different than Angelos was not justified. Id. That is, absent stipulation to the contrary,

modification of the occupancy of the homestead * * * should be allowed only when the party seeking modification can show a material change in circumstances.

Angelos, 372 N.W.2d at 407-08 (emphasis added). See also Erickson v. Erickson, 434 N.W.2d 284, 286-87 (Minn.App.1989) (reversing trial court’s ordered sale of homestead in spite of parties’ stipulation to cohabitation provision. Held that provision was unenforceable because it failed to provide for specific consequences. Court also relied on Angelos holding “no change in circumstances * * * which would justify * * * modification in the occupancy of the homestead”).

Respondent argues the postponement of the satisfaction of the lien deals with the division of property and has nothing to dp with maintenance or child support. Therefore, respondent continues, there is no need to determine whether there has been a change in circumstances in order to trigger the satisfaction of the lien on the homestead in favor of respondent. We disagree. While respondent’s lien is part of the property division and not subject to modification, the postponement of his lien is in the nature of child support and subject to modification. See Thomas, 356 N.W.2d at 78 (postponement of lien operates to encourage occupancy by minor children and as such renders postponement provision one for child support rather than property division).

Appellant has primary physical custody of the parties’ minor child. Here, postponing respondent’s lien encourages the minor child’s occupancy of the homestead. Therefore the postponement provision is in the nature of child support and could be modified only upon a showing of a change in circumstances. See id.

*914Again, we acknowledge that this case does not involve modification of an earlier decree. However, if the disputed provision is allowed to stand, a change in the occupancy of the homestead would be effectuated automatically, absent stipulation by the parties,1 upon the occurrence of cohabitation by appellant without addressing whether there has been a change in circumstances. We find such a provision to be inconsistent with Minnesota law.2

We also find public policy considerations support our conclusion. The supreme court has stated that participation in a meretricious relationship by a cohabitating couple does not, simply by reason of the relationship, justify reduction or termination of spousal maintenance. Mertens v. Mertens, 285 N.W.2d 490, 491 (Minn.1979); Abbott v. Abbott, 282 N.W.2d 561, 565 (Minn.1979); Bateman v. Bateman, 382 N.W.2d 240, 251 (Minn.App.1986), pet. for rev. denied (Minn. Apr. 24, 1986). Rather, the cohabitation should only be considered “insofar as it might improve an ex-spouse’s economic well-being.” Mertens, 285 N.W.2d at 491 (quoting Sieber v. Sieber, 258 N.W.2d 754, 758 (Minn.1977)).

[Ljiving with another individual, male or female, does not automatically trigger an economic dependency and certainly does not result in the attachment of legal consequences.

Bateman, 382 N.W.2d at 251. The arrangement can be broken off without obligation. If maintenance were automatically modified, the likelihood the former spouse may need public assistance is increased. Abbott, 282 N.W.2d at 565. We feel the same public policy considerations apply here and in fact, weigh heavily in our decision.

Based on the trend of Minnesota case law and public policy considerations, to in-elude a provision in a final decree that would mandate a change in the occupancy of the homestead upon cohabitation by the occupying spouse, absent stipulation to the contrary, is an error of law. We note our holding is narrow and specifically limited to cohabitation clauses only.

DECISION

The trial court erred as a matter of law by including the disputed provision in the final judgment and decree. We remand to the trial court to strike paragraph 8(b)(4) from the judgment and decree.

Reversed and remanded.

. The parties contested the provision here at issue and made their respective arguments to the trial court. Although appellant stated in her letter brief to the trial court that it had "discretion” to include the disputed provision in the judgment and decree, this statement does not appear as part of her legal argument to the trial court. Rather, the statement appears to be nothing more than an acknowledgment of the trial court’s role as decisionmaker.

. We acknowledge that the Minnesota Supreme Court has allowed a similar provision to stand in a judgment and decree. See Rohling v. Rohling, 379 N.W.2d 519, 523 (Minn.1986). However, the cohabitation provision in Rokling was neither challenged by the parties in that case nor addressed by the court. The case was decided on other grounds. See id. at 523. Therefore, it is not binding precedent as to the issue before us.