Jessica Robertson, Volume 50 Articles Editor
JUSTICE GUZMAN DELIVERED THE OPINION OF THE COURT.
The objective of the Court in this case was to clarify the acceptance-of-benefits doctrine as a fact-dependent, estoppel-based doctrine focused on preventing unfair prejudice to an opposing party. The Supreme Court of Texas held that a merits-based disposition must not be abandoned without disadvantage to the opposing party and certain circumstances that reflect intent to acquiesce in the judgment’s validity.
In Kramer v. Kastleman, Kastleman moved to dismiss Kramer’s appeal under the acceptance-of-benefits-doctrine following an extensive divorce proceeding. The court of appeals granted the motion after finding that Kramer had undisputedly accepted benefits in excess of $1 million in assets and funds since the settlement agreement that Kramer wished to appeal. Kramer now argues that dismissal is not appropriate unless acceptance of the benefits under the divorce decree prejudiced the other spouse or has otherwise acquiesced in the judgment.
The acceptance-of-benefits doctrine precludes a party from initially adopting a judgment then repudiating the judgment and taking advantage from the inconsistency. Because the doctrine is purely based in equity, a party is barred from appeal if the party asserting the doctrine proves all essential elements to establish estoppel. This Court has only considered the doctrine’s application as it pertains to divorce proceedings in one case before Kramer. Consequently, this case presented an opportunity for the Court to clarify and illuminate the doctrine in light of the circumstances.
The Court analyzed the doctrine with an emphasis on equity, further defining the narrow exceptions to the doctrine and evaluating nonexclusive factors of estoppel. This analysis led to the conclusion that courts must refrain from formulaic principles and hardline rules that interfere with the equitable nature of the doctrine and must adjudge the doctrine against any unfair prejudice to prove application of the doctrine is proper.
Kramer v. Kastleman, No. 14-1038 (Tex. Jan. 27, 2017).