Tuesday, January 6, 2009

Equity in family law -- unmarried couples do not have rights in Equity similar to those of married couples

Today’s decision in Belvedere v. Brittain Estate, 2009 ONCA 1 considers in detail the use of Equity in the context of cohabiting but unmarried couples. A fair summary would be that the case strongly limits the use of trusts in family law except where there is a very clear case of uncompensated contributions to property. Put otherwise, a court is not entitled to impose a “marriage like” settlement on an unmarried couple by use of Equity. The case is of great importance in the context of the end of an unmarried couple’s relationship and is worthy of close review in that context.

Here the couple’s relationship ended with the unexpected death of one of the two. Prior to death the deceased had expressed an intention to settle certain assets with his partner but by death had not done so. There was paperwork prepared for the settlement but death intervened. Despite this, Equity was not entitled to intervene and complete the settlement as intended.

The Court writes:

[50] First, a constructive trust is available as a remedy for unjust enrichment only where monetary damages are inadequate: see Peter v. Beblow at p. 997. In this case, had unjust enrichment been established, monetary damages would clearly have been an adequate remedy. At the time of his death, Mr. Brittain’s estate was valued at approximately $6 million. There were more than adequate funds to compensate Ms. Belvedere for her claim of unjust enrichment.

[51] Second, in addition to the above requirement, there must be a link between the contribution that founds the action and the property in which the constructive trust is claimed: Peter v. Beblow at p. 988; see also Sorochan at p. 50. In this case, Ms. Belvedere did not contribute, directly or indirectly, to Mr. Brittain’s RRSPs, and whatever potential interest she might arguably have had would, in any event, be limited to Mr. Brittain’s last two payments of $13,500 per year during the time of the cohabitation.

[57] Where damages are the remedy for unjust enrichment, the trial judge ought to proceed on a “value received” approach: see Bell v. Bailey, (2001), 203 D.L.R. (4th) 589 (Ont. C.A.) at para. 38. In this case, the services Ms. Belvedere provided that arguably merit compensation were domestic labour, Air Canada travel and health benefits, and use of her family’s Florida condominium.

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Anonymous said...

This is interesting in the context where many modern couples to not get married and it seems that the "law" has not evolved with the times and social changes.

In Quebec, where more cohabit together without being married in terms of Canadian population it seems to lead to more injustices but all still perfectly legal...

But then again, it does seem that the courts are basing themselves on notions of "family and marriage" even if a couple is not married. This takes on a larger aspect about our culture and values.

The law, when it comes to children in cases of separation of cohabiting couples is rather cruel towards the "father figure" and justice is expensive. No wonder so many give up....

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She got exactly what she deserved. Nothing. The award of 1.75 million was so egregious in this situation as to be legally laughable. Easiest decision ever written by an appeals court EVER. Greed never pays off and too bad she learned this hard way.

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