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Decision Information

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Facts

  • The petitioner-appellant, Wife, appealed the district court's enforcement of a marriage settlement agreement (MSA) she entered into with the respondent-appellee, Husband. After mediation, both parties signed the MSA, but Wife later sought to rescind it, claiming she signed under duress and without fully understanding the terms. The district court also awarded fees and costs to Husband's counsel and enforced a charging lien by Wife's former counsel. Wife alleged judicial misconduct and deprivation of due process (paras 1-3, 5-14).

Procedural History

  • District Court of San Miguel County, Gerald E. Baca, District Judge: Enforced the MSA, awarded fees and costs to Husband’s counsel, and enforced a charging lien by Wife’s former counsel.

Parties' Submissions

  • Petitioner-Appellant (Wife): Argued that the MSA should be rescinded due to her signing under duress and without a full understanding of the terms. Claimed judicial misconduct and deprivation of due process.
  • Respondent-Appellee (Husband): Argued for the enforcement of the MSA, stating that it was entered into voluntarily and with a full understanding by both parties.
  • Claimant-Appellee (Martin Lopez III, P.C.): Sought enforcement of a charging lien for unpaid legal fees and costs.

Legal Issues

  • Whether the district court erred in enforcing the MSA despite Wife's claims of duress and lack of understanding.
  • Whether the district court erred in awarding fees and costs to Husband’s counsel.
  • Whether the district court erred in enforcing the charging lien by Wife’s former counsel.
  • Whether the district court judge engaged in misconduct, thereby depriving Wife of due process.

Disposition

  • The Court of Appeals affirmed the district court's decisions on all issues (para 1).

Reasons

  • The Court of Appeals found that the district court did not abuse its discretion in enforcing the MSA, awarding fees and costs to Husband's counsel, and enforcing the charging lien by Wife's former counsel. The court reviewed the district court's decisions for abuse of discretion and found substantial evidence supporting the decisions. The court noted that Wife was an active participant in the settlement negotiations and had affirmed her understanding and voluntary agreement to the MSA terms during a court colloquy. The court also found the awarded attorney fees and costs to be reasonable and supported by the circumstances of the case. The court rejected Wife's claims of judicial misconduct due to lack of preservation and support in the record. Additionally, the court granted attorney fees and costs on appeal to Martin Lopez III, P.C., due to the frivolous nature of Wife's claims against him (paras 18-53).
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