Court of Appeals of the District of Columbia
881 A.2d 630 (D.C. 2005)
Brian Duffy (defendant) and Joan Duffy (plaintiff) divorced. The Duffys negotiated a separation agreement, which Joan drafted in the form of a letter to her lawyer. The letter agreement included child-support obligations for Brian. Both Brian and Joan signed the letter. Brian and Joan agreed that the lawyer would reduce the letter to a formal agreement that could be reviewed by Brian’s lawyer. Brian never signed the agreement drafted by Joan’s lawyer, but abided by the terms of the letter for a more than a year until Brian unilaterally reduced his child-support payments. Joan filed a petition to enforce the settlement agreement, including the child-support obligations, as contained in the letter. The trial court found that the letter agreement was enforceable. Brian appealed, arguing that the letter was unenforceable and that the letter should have contained a provision for reducing his child-support obligations if, for example, he lost his job.
Rule of Law
Holding and Reasoning (Ruiz, J.)
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