Utah Court of Appeals
Can a postnuptial agreement requiring percentage-based alimony payments be enforced without detailed payment terms? Taylor v. Taylor Explained
Summary
Jacqueline Taylor appealed the district court’s determination that alimony provisions in a postnuptial agreement were unenforceable for lacking essential terms. The agreement required Mark Taylor to pay alimony equal to at least 20% of his income (30% if infidelity occurred), but the court found it failed to specify payment schedules, income calculation procedures, and modification terms.
Practice Areas & Topics
Analysis
In Taylor v. Taylor, the Utah Court of Appeals addressed whether a postnuptial agreement’s alimony provisions were enforceable when they lacked specific procedural terms for calculating and paying support.
Background and Facts
Jacqueline and Mark Taylor executed a postnuptial agreement in Texas that modified their prenuptial agreement’s alimony waiver. The postnuptial agreement required Mark to pay Jacqueline at least 20% of his income as alimony (30% in case of infidelity). When Jacqueline filed for divorce in Utah, the district court ruled the alimony provisions unenforceable, finding they lacked essential terms including: payment schedules, procedures for determining income, modification schedules, and effective dates for updated calculations.
Key Legal Issues
The central issue was whether the postnuptial agreement’s alimony provisions were sufficiently definite to be enforceable under Texas law, which governed the agreement. The district court had concluded that missing procedural terms rendered the agreement too indefinite to enforce.
Court’s Analysis and Holding
The Court of Appeals reversed, applying Texas contract principles that favor avoiding forfeitures based on indefinite terms. The court found that most challenged terms could be supplemented by reference to applicable state alimony laws, which provide default rules for payment timing, modification procedures, and effective dates. For the undefined term “income,” the court looked to Texas Family Code Section 8.055(a-1), which defines “gross income” for alimony calculations, concluding this definition should supplement the agreement’s use of “income.”
Practice Implications
This decision demonstrates that Utah courts will apply the governing state’s contract interpretation principles, including preferences for avoiding forfeitures. When challenging agreements for indefiniteness, practitioners should consider whether the governing jurisdiction’s statutes provide mechanisms to supplement missing terms. The decision also highlights the importance of carefully drafting choice-of-law provisions, as they can significantly impact enforceability determinations.
Case Details
Case Name
Taylor v. Taylor
Citation
2025 UT App 94
Court
Utah Court of Appeals
Case Number
No. 20230868-CA
Date Decided
June 26, 2025
Outcome
Reversed
Holding
A postnuptial agreement requiring alimony payments based on a percentage of income is sufficiently definite under Texas law when read in conjunction with applicable state alimony statutes and Texas’s definition of gross income.
Standard of Review
Correctness for summary judgment and contract interpretation
Practice Tip
When challenging contract enforceability based on indefinite terms, consider whether the governing state’s law provides mechanisms to supplement missing terms through statutory definitions or judicial discretion.
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Lotus Appellate Law handles appeals before the Utah Court of Appeals, Utah Supreme Court, California Court of Appeal, and the United States Court of Appeals for the Tenth Circuit.
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Lotus Appellate Law publishes these summaries to keep practitioners informed — not as legal advice. Each case turns on its own facts. If a decision here is relevant to your matter, we’re happy to discuss it.