Brooks v. Minn

In Brooks v. Minn, 73 Haw. 566, 73 Haw. 566, 836 P.2d 1081 (1992), the divorcing parties entered into a property settlement agreement (PSA) that stated that Minn was to pay Brooks $ 60,000 in accordance with a promissory note executed by Minn. Id. at 568, 836 P.2d at 1083. The PSA was then approved by the family court and incorporated into a final divorce decree. Id. at 569, 836 P.2d at 1083. After Minn failed to pay Brooks according to the terms of the note, Brooks filed a complaint against Minn seeking to collect the amounts due under the note. Id. The circuit court rendered a judgment in favor of Brooks. Id. at 570, 836 P.2d at 1084. On appeal, the Hawaii Supreme Court disagreed with the circuit court and ruled that "the incorporation of the PSA into the divorce decree merged the PSA into the final divorce decree; therefore, the note no longer had any independent existence and was not enforceable as a contract, but only as an element of the family court's final judgment." Id. at 571-72, 836 P.2d at 1084.