Summary
The Rhode Island Supreme Court affirmed a Family Court order enforcing an arbitrator's determination that private high school tuition constituted a reasonable educational expense under the parties' property settlement agreement. The court held that the Family Court had jurisdiction to enforce the settlement agreement and subsequent consent order, rather than to confirm an arbitration award under the Rhode Island Arbitration Act. Although the trial justice should have reviewed the decision under child-support principles, the error was harmless because the record did not show that the decision was inequitable or contrary to the child's best interests.
Topics
Practice areas
Questions Presented
- Whether the Family Court had subject-matter jurisdiction to enforce the parties' property settlement agreement and subsequent consent order requiring them to submit the educational-expense dispute to arbitration.
- Whether the Family Court erred by enforcing the arbitrator's decision without meaningfully reviewing it under applicable child-support principles.
Holdings
- The Family Court had subject-matter jurisdiction because it was enforcing a property settlement agreement and a subsequent consent order concerning child-support-related educational expenses, rather than confirming or vacating an arbitration award under the Rhode Island Arbitration Act.
- The Family Court was required to review the arbitrator's determination to determine whether it was inequitable to the parties or contrary to the child's best interests; however, the trial justice's failure to conduct that review was harmless because the record showed no inequity or adverse effect on the child's best interests.
Key quotations
“The Family Court did not order the parties to arbitrate, nor did it confirm an arbitration award; it merely enforced the property settlement agreement and subsequent consent order in which both parties agreed to submit their dispute to arbitration.” (78)
“Thus, we are of the opinion that the hearing justice should have reviewed the arbitrator's decision to determine whether his conclusion was inequitable to the parties or was in the child's best interest.” (79)
Factual background
The parties' non-merged divorce settlement agreement required Edward to pay all reasonable grammar and high school tuition and tutoring expenses for their four minor children. When the parties disagreed about their oldest son's private school, they agreed that he would attend the Forman School and later consented to arbitration concerning whether the tuition was a reasonable expense. The arbitrator found the Forman School tuition reasonable based in part on the parties' lifestyle and Edward's income when the agreement was executed.
Procedural history
The parties' divorce judgment incorporated a non-merged property settlement agreement requiring the husband to pay reasonable grammar and high school expenses and providing for binding arbitration if the parties could not agree. After the parties consented to arbitration concerning their son's 2004-2005 and 2005-2006 educational expenses, the arbitrator found the Forman School tuition reasonable. The Family Court enforced the decision, and the Rhode Island Supreme Court affirmed, while remanding for proceedings consistent with its opinion.
Remand instructions
The record was remanded to the Family Court for proceedings consistent with the Supreme Court's decision, including review of the arbitrator's determination under applicable child-support principles.