Pyeatte v. Pyeatte

Arizona Court of Appeals · 1982 · Contracts

Contractsquasi-contractunjust enrichmentmarriagelaw school supportindefinitenessoral agreementspousal education support

Facts

During marriage, the spouses agreed that the wife would support the husband through three years of law school without his having to work, and then the husband would support the wife while she obtained a master's degree without working. The wife fully performed by supporting both spouses during most of law school and contributing significantly to savings used during the final year, while the husband completed law school and was admitted to the bar. After graduation, the parties deferred the wife's education because his starting salary was insufficient to support both the marriage and her schooling at once. Soon afterward, the husband said he no longer wanted to be married, the wife petitioned for dissolution, there was little community property, and no spousal maintenance was sought or awarded.

Issue

Was the spouses' oral agreement sufficiently definite to be enforceable as a contract, and if not, could the wife still recover in restitution for the financial support she provided for the husband's legal education when the marriage ended shortly after his graduation and before she received the reciprocal benefit? Also, could reimbursement be awarded under A.R.S. § 25-318 as a property-related remedy?

Rule

A binding contract requires sufficiently definite and certain essential terms so that the parties' obligations can be fixed with certainty; courts may not supply missing essential terms and thereby make a contract for the parties. Even absent an enforceable contract, restitution in quasi-contract is available where one party conferred a benefit on another, the recipient was unjustly enriched at the provider's expense, and the circumstances make compensation required in good conscience. In the marital context, restitution is not available for ordinary marital or homemaking contributions, but it is appropriate when there is an agreement plus an extraordinary or unilateral effort by one spouse that by dissolution has inured solely to the benefit of the other, especially where the marriage ends soon after the supported spouse completes the education and there is little or no marital property.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Dana Ortiz and Colin Mercer orally agreed during marriage that Dana would work full time and cover household expenses while Colin attended engineering school, and later Colin would support Dana while she pursued "some kind of graduate training." They never discussed when Dana would enroll, where she would study, how long the program would last, or what expenses Colin would have to pay. The marriage ended two months after Colin received his license, before Dana began any program.

If Dana sues for breach of the oral agreement, what is the strongest argument against enforcing it as a contract?

Explanation. A binding contract requires sufficiently definite essential terms so the parties' liabilities can be exactly fixed. Where the parties did not agree on material points such as timing, place, duration, and cost of the claimant spouse's future education, the court may not supply those missing terms and create a contract for them. The majority rejected the notion that such a vague reciprocal education-support promise could be enforced for expectation damages.