Kramer v. Kastleman (Opinion)Annotate this Case
During their marriage, Respondent and Petitioner produced one child and a $30 million marital estate. During marriage-dissolution proceedings, the parties executed two agreements settling all issues. The trial court orally approved the settlement agreements and granted the divorce petitions, and more than one year passed before the trial court’s rulings were reduced to writing in a final divorce decree. Petitioner filed several post-judgment motions challenging the decree, arguing that the child support and child custody provisions in the final decree materially deviated from the parties’ agreement. The trial court substantially denied Petitioner relief. Petitioner appealed, challenging the property division and child welfare provisions of the divorce decree. Applying the estoppel-based acceptance-of-benefits doctrine, which preludes a litigant from challenging a judgment after voluntarily accepting the judgment’s benefits, the court of appeals dismissed the appeal. The Supreme Court reversed, holding (1) the acceptance-of-benefits doctrine is a fact-dependent, estoppel-based doctrine focused on preventing unfair prejudice to the opposing party; and (2) the factors informing the equitable inquiry did not favor an estoppel in this case.