AMANDA MALONE COURVILLE v. STONEY JAMES COURVILLE (2026)

NOTICE OF JUDGMENT AND CERTIFICATE OF MAILING

NOTICE IS HEREBY GIVEN that the attached judgment and written opinion was rendered this date and a copy was mailed to the trial judge, all counsel of record and all parties not represented by counsel as listed above.

FOR THE COURT

Renée R. Simien Clerk of Court

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

26-18

AMANDA MALONE COURVILLE

V.

STONEY JAMES COURVILLE

Judgment rendered and mailed to all parties or counsel on October 30, 2026. Applications for rehearing may be filed within the delays allowed by La. Code Civ. P. art. 2166 or La. Code Crim. P. art. 922.

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2016-3938 HONORABLE W. MITCHELL REDD, DISTRICT JUDGE

LEDRICKA J. THIERRY JUDGE

Court composed of Van H. Kyzar, Candyce G. Perret, and Ledricka J. Thierry, Judges.

VHK

CGP

LJT

AFFIRMED.

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

26-18

AMANDA MALONE COURVILLE

V.

STONEY JAMES COURVILLE

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2016-3938 HONORABLE W. MITCHELL REDD, DISTRICT JUDGE

LEDRICKA J. THIERRY JUDGE

Court composed of Van H. Kyzar, Candyce G. Perret, and Ledricka J. Thierry, Judges.

AFFIRMED.

Jennifer E. Jones Clare Burke Walter M. Sanchez Sanchez Burke, LLC 1200 Ryan Street Lake Charles, LA 70601 (337) 433-4405 COUNSEL FOR PLAINTIFF/APPELLANT/APPELLEE Amanda Malone Courville

John Green, Jr. Law Office of John Green, Jr. 1135 Hodges Street Lake Charles, LA 70601 (337) 990-0060 COUNSEL FOR DEFENDANT/APPELLEE/APPELLANT Stoney James Courville

THIERRY, Judge.

In this dispute between a divorced couple, both parties appeal portions of the trial court's judgment involving a transfer of immovable property and payments of health insurance and gas expenses. For the reasons that follow, we affirm the trial court's judgment.

FACTS AND PROCEDURAL HISTORY

Stoney James Courville and Amanda Malone Courville ¹ married in 1994 and divorced in 2016. After the judgment of divorce was rendered, the parties engaged in several stipulated judgments, written contracts, and “handshake” deals to divide their community assets and debts. At issue in this appeal are three of those agreements.

The first is a Stipulated Judgment filed on November 2, 2016 (“2016 Stipulated Judgment”), in which the parties purported to terminate the community property regime and stipulated, in relevant part, that (1) Amanda be awarded exclusive use of the 2014 Jeep Rubicon (“Jeep”) and 2015 Cadillac CTS (“Cadillac”); (2) Amanda “be liable for any and all maintenance and insurance on” the Jeep and Cadillac; (3) Stoney be liable for all of Amanda's monthly gas expenses for her use of the Jeep, Cadillac, “and for any other vehicles [Amanda] may use[;]” and (4) Stoney be required to maintain health insurance for Amanda. The parties reserved their right to formally partition their community property at a later date.

Next, on January 4, 2017, a second, more comprehensive stipulated judgment was filed, entitled “Stipulated Judgment of Community Property Partition” (“2017 Stipulated Judgment”), which expressed the parties’ desire “to compromise and settle all issues between them concerning the partition of their community property.” The 2017 Stipulated Judgment stipulated, among other things, that any and all proceeds from the sale of property located at 4014 Goos Ferry Road in Lake Charles, Louisiana (“the Goos Ferry Road property”) would be equally shared by the parties. It also stipulated that Amanda agreed to discharge Stoney from several obligations and liabilities, including “[a]ny and all debts associated with the 2014 Jeep Rubicon, including but not limited to the monthly note, maintenance and insurance[,]” and “[a]ny and all debts associated with the 2015 Cadillac CTS, including but not limited to the monthly note, maintenance and insurance[.]” This stipulation was silent regarding Amanda's gas expenses.

The third contract at issue is a December 29, 2017 Quit Claim Deed, whereby Cramer-Gene Properties, LLC, represented by Amanda who was its sole member, transferred ownership of the Goos Ferry Road property to Stoneville Properties, LLC, represented by Stoney who was its sole member.

Approximately four years after the execution of the Quit Claim Deed, Amanda filed a Motion to Rescind Partition for Lesion or Alternatively, Motion to Enforce Partition;² Motion to Anull [sic] Quitclaim Deed for Failure of Consideration; and Motion to Enforce Acknowledgment and Agreement with Respective Memorandums [sic] Incorporated. In the Motion to Enforce Partition, Amanda alleged that the Goos Ferry Road property was co-owned by her and Stoney, but he did not allow her to use it. She also alleged that Stoney failed to continue to provide her health insurance since March 16, 2021. In the Motion to Anull [sic], she argued that the Quit Claim Deed should be declared an absolute nullity due to failure of consideration. Thereafter, Amanda filed a Notice of Lis Pendens to provide notice of this filing. In October 2022, Stoneville Properties, LLC sold the Goos Ferry Road property to a third party for $500,000.00.

On September 3, 2022, Amanda remarried.

In November 2022, Amanda filed a Rule for Contempt, Attorney's Fees and Costs; and Motion to Partition Partial Community Property. She alleged that pursuant to the 2016 Stipulated Judgment, Stoney was liable for her monthly gas expenses for her use of the Jeep, Cadillac, “and for any other vehicles that Amanda may use, in perpetuity.” She alleged that Stoney cancelled her gas card on or about September 6, 2022, which violated the 2016 Stipulated Judgment. She further alleged that Stoney failed to maintain health insurance for her since March 2021, which also violated the 2016 Stipulated Judgment.

In December 2022, Stoney filed a Petition to Terminate Interim Period Spousal Support. He claimed that since Amanda remarried on September 3, 2022, he was no longer responsible for paying for her health insurance or gas expenses.

On January 19, 2023, the parties attended a Hearing Officer Conference. The hearing officer noted in his findings: “Amanda argues that Stoney's obligation to indefinitely pay her gasoline and health insurance expenses was negotiated in exchange for her agreement to not delve deeply into Stoney's matters (and his business partners’ matters) in the parties’ community property partition.” The hearing officer ultimately recommended that Stoney's obligations to pay Amanda's health insurance and gas expenses terminated upon her remarriage. The hearing officer also recommended that Stoney pay $6,716.09 to Amanda, which was the amount of past due health insurance and gas expenses.

In 2025, the trial court heard these matters. In its Written Reasons and Judgment, the trial court held that (1) the Quit Claim Deed was valid; and (2) the provisions in the 2016 Stipulated Judgment requiring Stoney to pay Amanda's gas expenses and health insurance were contractual, clear, and did not constitute spousal support. The trial court subsequently formalized this ruling,³ in which it denied Amanda's Motion to Anull [sic] and Motion to Enforce Partition as it related to the Goos Ferry Road property. The court also denied Stoney's Petition to Terminate Interim Period Spousal Support. Both Amanda and Stoney filed timely appeals of this judgment.

ASSIGNMENTS OF ERROR

Amanda raises several assignments of error concerning the Quit Claim Deed, namely that: (1) the trial court legally erred in interpreting the Quit Claim Deed; (2) the trial court manifestly erred by finding there was no evidence to support the contention that Stoney needed ownership of the Goos Ferry property in order to sell that property; (3) the trial court legally erred in finding there was consideration for the sale; (4) the trial court legally erred by finding that the presumption in La.Civ.Code art. 2480 did not apply to Amanda, the seller; and (5) the trial court legally erred by denying the Motion to Enforce Partition and not requiring Stoney to executive corrective title.

In Stoney's appeal, he alleges that the trial committed legal error when (1) it did not find that the order requiring him to pay Amanda's health insurance and gas expenses was an alimentary obligation as part of permanent periodic support; and (2) it held that Stoney's obligation to pay Amanda's health insurance and gas expenses did not terminate upon Amanda's remarriage, pursuant to La.Civ.Code art. 115.

ANALYSIS

Amanda's Appeal

Amanda's appeal concerns the Quit Claim Deed, which transferred the Goos Ferry Road property from Amanda's LLC to Stoney's LLC. The Quit Claim Deed states, in relevant part:

CRAMER-GENE PROPERTIES, LLC a Louisiana limited liability company ․ herein represented by Amanda Lucy Cramer (formerly known as Amanda Courville), its duly authorized sole member, domiciled in Calcasieu Parish, Louisiana, ․ hereinafter referred to as “vendor”,

who, after being duly sworn, did declare that it does, for and in consideration and on the terms and conditions hereinafter expressed, vendor does hereby sell, transfer, assign, quit claim, convey, assign, and deliver, with full warranty of title and with full subrogation to all rights and actions of warranty of said vendor, against all former owners and vendors, unto:

STONEVILLE PROPERTIES, LLC a Louisiana liability company ․ herein represented by Stoney Courville, its duly authorized sole member, domiciled in Calcasieu Parish, Louisiana, ․ hereinafter referred to as “vendee”,

and vendee accepting for itself, its successors, heirs and assigns, and acknowledging due delivery and possession thereof, all and singular, of the following described property, situated in the Parish of Calcasieu, State of Louisiana, to-wit:

Lot Two (2) of Diamond Development, Inc., Tract 4, a subdivision of the North Half (N/2) of Section 11, Township 9 South, Range 8 West, lying West of Calcasieu River, as per plat recorded in Plat Book 34, page 109, records of Calcasieu Parish, Louisiana, together with all buildings and improvements situated thereon.

This sale is made and accepted subject to the restrictive covenants, easements, right-of-ways, mineral reservations, mineral leases and obligations ownership, etc., filed in parish records.

Bearing Municipal Address: 4014 Goos Ferry Road, Lake Charles, Louisiana 70615.

TO HAVE AND TO HOLD the above-described property unto the said vendee, its successors and assigns forever.

The sole members of the parties hereto entered into a Stipulated Judgment to partition their community property. Pursuant to same, Amanda Courville, now Amanda Lucy Cramer, retained all of the assets and liabilities related to CRAMER-GENE PROPERTIES, LLC ․ The parties intended for Stoney Courville to retain ownership of the property quit claimed herein which was actually in the name of CRAMER-GENE PROPERTIES, LLC. Accordingly, in order to facilitate and accomplish the true intent of the parties as set forth in the Community Property Partition, the parties execute the Quit Claim herein in order to transfer this property to an LLC in which Stoney Courville is the sole member.

THIS SALE IS MADE and ACCEPTED for and in consideration of avoidance of litigation and to facilitate the agreement referenced above and for the same consideration set forth therein which the said vendee has well and truly paid, in ready and current money, to the said vendor, who hereby acknowledges receipt thereof and grants full acquittance and discharge therefore.

Interpreting a contract is a question of law, with the appellate court applying the de novo standard of review. Cregg v. Bd. of Supervisors of La. State Univ. & Agric. & Mech. Coll., 23-127 (La.App. 1 Cir. 3/1/24), 385 So.3d 280, writ denied, 24-409 (La. 6/5/24), 385 So.3d 1158. However, where factual findings are relevant to interpreting a contract, the appellate court applies the manifest error standard of review. Clinkscales v. Columns Rehab. & Ret. Ctr., 08-1312 (La.App. 3 Cir. 4/1/09), 6 So.3d 1033. We apply the de novo standard of review to Amanda's first two assignments of error and the manifest error standard of review to her assignments of error involving simulation, as the trial court made factual findings when it heard and considered the trial testimony.

a. Interpretation of the Quit Claim Deed

Amanda's first two assignments of error concern the trial court's interpretation of the Quit Claim Deed and denial of her Motion to Enforce Partition.

The Quit Claim Deed is a contract, defined by our Civil Code as an agreement between parties in which “obligations are created, modified, or extinguished.” La.Civ.Code art. 1906. “Interpretation of a contract is the determination of the common intent of the parties.” La.Civ.Code art. 2045. “When the words of a contract are clear and explicit and lead to no absurd consequences, no further interpretation may be made in search of the parties’ intent.” La.Civ.Code art. 2046. It is well-settled that “a contract may be modified by the mutual consent of the parties.” Vinet v. Est. of Calix, 03-572, p. 5 (La.App. 5 Cir. 10/28/03), 860 So.2d 160, 163.

Amanda argues that the trial court erred when it concluded that the December 2017 Quit Claim Deed modified the January 2017 Stipulated Judgment.⁴ The 2017 Stipulated Judgment provides that the parties would equally share any net proceeds from the sale of the Goos Ferry Road property, while the Quit Claim Deed transfers ownership of that property to Stoney through his LLC. Amanda claims that the Quit Claim Deed does not modify the 2017 Stipulated Judgment, but rather effectuates it and entitles her to one-half of the proceeds from the 2022 sale of the property. We disagree.

The Quit Claim Deed, which was drafted by Amanda's attorney, references the 2017 Stipulated Judgment and expressly explains that it serves “to facilitate and accomplish the true intent of the parties[.]” The Quit Claim Deed further reflects the parties’ intent for Stoney to retain the Goos Ferry Road property and purports to accomplish that intent. Notably, the Quit Claim Deed does not provide that the proceeds from the sale should be shared between Stoney and Amanda. Rather, the plain and explicit language of the Quit Claim Deed transfers the Goos Ferry Road property from Amanda's LLC, Cramer-Gene Properties, LLC, to Stoney's LLC, Stoneville Properties, LLC. Accordingly, we find no error in the trial court's denial of Amanda's Motion to Enforce Partition, as the 2017 Stipulated Judgment was modified by the mutual consent of both Amanda and Stoney when they executed the Quit Claim Deed.

Amanda also contends that the trial court erred when it stated in its Written Reasons and Judgment that “[n]o testimony or evidence at trial supported [Stoney's] ability to sell the property as a basis for the necessity of the quitclaim deed.” As previously noted, the words of the Quit Claim Deed are clear and unambiguous. Regardless of the parties’ testimony regarding their intent or understanding of the Quit Claim Deed, we are not permitted to further interpret the parties’ intent. See La.Civ.Code arts. 2046 and 1848.⁵ The trial court referenced the trial testimony in this portion of its Written Reasons and Judgment, but it also recognized that the language of the Quit Claim Deed was “clear and unambiguous.” We find no reversible error, and these assignments of error lack merit.

b. Alleged Simulation

Amanda's next two assignments of error concern the trial court's denial of her Motion to Anull [sic] and its failure to recognize the Quit Claim Deed transaction as a simulation. She argues that the trial court erred by finding that (1) there was consideration for the sale, and (2) the presumption in La.Civ.Code art. 2480 was inapplicable.

“A contract is a simulation when, by mutual agreement, it does not express the true intent of the parties.” La.Civ.Code art. 2025. A simulation can be absolute, “when the parties intend that their contract shall produce no effects between them,” or relative, “when the parties intend that their contract shall produce effects between them though different from those recited in their contract.” La.Civ.Code arts. 2026, 2027. Under La.Civ.Code art. 1848 cmt. (c), “testimonial or other evidence is admissible to prove an absolute or relative simulation.”

First, we address Amanda's argument regarding the presumption in La.Civ.Code art. 2480. Generally, the burden of proof rests on the party alleging a simulation, who must prove such with reasonable certainty. Bennett v. Porter, 10-1088 (La.App. 3 Cir. 3/9/11), 58 So.3d 663. However, La.Civ.Code art. 2480 provides an exception: “When the thing sold remains in the corporeal possession of the seller the sale is presumed to be a simulation, and, where the interest of heirs and creditors of the seller is concerned, the parties must show that their contract is not a simulation.” The predicate fact of this article is the seller's corporeal possession. Corporeal possession is defined as “the exercise of physical acts of use, detention, or enjoyment over a thing.” La.Civ.Code art. 3425.

Amanda argues that she retained corporeal possession of the Goos Ferry Road property so as to trigger the presumption in La.Civ.Code art. 2480. We disagree. The record is sparse regarding Amanda's alleged possession of the Goos Ferry Road property, revealing that she sometimes used the property with Stoney's permission, stopped using the property when Stoney allegedly asked her to, and did not pay for property taxes or improvements. The record is silent regarding how often Amanda stayed at the property, how long she stayed when she visited, and whether she even spent the night there. Our review of the record does not support Amanda's contention that the Goos Ferry Road property remained in her corporeal possession following execution of the Quit Claim Deed. Accordingly, La.Civ.Code art. 2480 is inapplicable.

Next, we consider whether the Quit Claim Deed was a simulation due to lack of consideration, or more aptly, cause.⁶ The jurisprudence has long held “that any sale which is accompanied by any consideration, no matter how slight, is not a simulation.” Bell v. Bell, 339 So.2d 1333, 1336 (La.App. 3 Cir. 1976); see also Bennett v. Porter, 10-1088 (La.App. 3 Cir. 3/9/11), 58 So.3d 663. In other words, “if any consideration supports the transaction; the reality of the transference is thus established.” Entergy La., Inc. v. Kennedy, 03-166, p. 8 (La.App. 1 Cir. 7/2/03), 859 So.2d 74, 80, writ denied, 03-2201 (La. 11/14/03), 858 So.2d 430.

Amanda testified at trial that the parties transferred ownership of the Goos Ferry Road property from her LLC to Stoney's LLC because Stoney was the one who would handle the sale of that property. She expected to receive half of the proceeds when the property was sold. She further testified that Stoney was the one who “would wheel and deal[,]” but later clarified that she had no idea why the Quit Claim Deed was needed. Stoney denied that the sale was executed for the necessity of the sale, as urged by Amanda, and that “[i]t was part of the deal [he and Amanda] made[.]”

Amanda further contends that no consideration was paid for the transfer of the property. The Quit Claim Deed specified that the sale was made “in consideration of avoidance of litigation and to facilitate the [2017 Stipulated Judgment] and for the same consideration set forth therein which the said vendee has well and truly paid, in ready and current money, to the said vendor, who hereby acknowledges receipt thereof ․” At trial, both Amanda and Stoney testified that no money was given when the quit claim deed was executed. However, the consideration, or cause, need not be monetary. Aaron & Turner, L.L.C. v. Perret, 07-1701 (La.App. 1 Cir. 5/4/09), 22 So.3d 910, writ denied, 09-1148 (La. 10/16/09), 19 So.3d 476.

Upon review of the record, we find no manifest error in the trial court's determination that the sale was not a simulation. The trial testimony revealed that, in addition to the consideration set forth in the Quit Claim Deed, the parties negotiated other bargains and agreements in conjunction with this deed. Furthermore, the plain language of the Quit Claim Deed corroborates that testimony, as the deed identifies the consideration as the avoidance of litigation, the facilitation of the 2017 Stipulated Judgment, and the consideration set forth in that judgment, which included the transfer of certain assets to Amanda. Collectively, these benefits constitute more than adequate consideration to refute Amanda's heavy burden of proving with reasonable certainty that the transfer was a simulation. Furthermore, Amanda's testimony that the Goos Ferry Road property was transferred to Stoney for selling purposes was contradicted by both Stoney's testimony and the plain language of the Quit Claim Deed. The trial court, as factfinder, was entitled to weigh the evidence and make credibility determinations. Jeanerette Lumber & Shingle Co., L.L.C. v. Shell Oil Co., 25-67 (La.App. 3 Cir. 9/24/25), 420 So.3d 858, writ denied, 25-1356 (La. 1/21/26), 425 So.3d 106. The trial court was not manifestly erroneous in deeming the Quit Claim Deed valid and denying Amanda's Motion to Annul. These assignments of error lack merit.

c. Corrective Documents

Finally, Amanda argues that even if we accept that the Quit Claim Deed modified the 2017 Stipulated Judgment, Stoney is still required to execute corrective documents to give Amanda one-half of the proceeds from the 2022 sale of the Goos Ferry Road property to a third party. In support, she cites to a provision in the 2017 Stipulated Judgment:

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that they declare that each of them shall immediately, when called upon to do so by the other party in writing, execute such additional or amendatory documents as may be necessary or required to vest title in the appropriate party or otherwise accomplish the provisions and agreements contained herein, and the parties agree to filing of public record of documents or extracts of documents to reflect ownership as provided herein. This provision is enforceable by summary proceedings[.]

Since we held that the trial court did not err by finding that the Quit Claim Deed modified the 2017 Stipulated Judgment, there is obviously no requirement for Stoney to execute an additional document vesting title in Amanda. This assignment of error is meritless.

Stoney's Appeal

Stoney's appeal concerns the trial court's denial of his Petition to Terminate Interim Period Spousal Support and order obligating him to pay Amanda's health insurance and gas expenses as set forth in the 2016 Stipulated Judgment. The relevant provisions in the 2016 Stipulated Judgment state:

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that AMANDA MALONE COURVILLE shall be awarded the exclusive use of the 2014 Jeep Rubicon and 2015 Cadillac CTS, and shall be liable for any and all maintenance and insurance on said vehicles;

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that STONEY JAMES COURVILLE shall be liable for any and all monthly gas expenses incurred on behalf of AMANDA MALONE COURVILLE for her use of the 2014 Jeep Rubicon and 2015 Cadillac CTS, and for any other vehicles that AMANDA MALONE COURVILLE may use, without the right of reimbursement;

․

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that STONEY JAMES COURVILLE shall maintain a policy of health insurance on behalf of AMANDA MALONE COURVILLE without the right of reimbursement[.]

Stoney argues that the court erred in finding that those expenses (1) were not alimentary obligations of permanent periodic support, and (2) did not terminate on the date Amanda remarried. Instead, he claims that these provisions are spousal support provisions, which terminated by law, pursuant to La.Civ.Code art. 115, when Amanda remarried.

a. Standard of Review

First, we identify the appropriate standard of review. The contract at issue in Stoney's appeal is the 2016 Stipulated Judgment. Louisiana courts have consistently held that stipulated judgments, or consent judgments, are binding compromises. See, e.g., Adrian v. Adrian, 15-419 (La.App. 3 Cir. 11/4/15), 178 So.3d 297; Sutherlin v. Sutherlin, 05-535 (La.App. 5 Cir. 2/3/06), 930 So.2d 51. “[A] judgment enforcing a compromise is reviewed pursuant to the manifest error standard of review.” Jeanerette Lumber, 420 So.3d at 865. “This is due in part to the fact that a ‘judgment regarding the existence, validity and scope of a compromise or settlement agreement hinges on its finding of the parties’ intent,’ which is a factual finding.” Adams v. Chevron USA, Inc., 22-814, p. 5 (La.App. 4 Cir. 5/3/23), 382 So.3d 229, 234, (quoting Eckstein v. Becnel, 17-868, p. 8 (La.App. 4 Cir. 6/27/18), 250 So.3d. 1046, 1053, writ denied, 18-1275 (La. 11/5/18), 255 So.3d 1054), writ denied, 23-855 (La. 10/10/23), 371 So.3d 454. In fact, this court has specifically held that the manifest error standard of review governs where divorced parties dispute the meaning or effect of a provision contained in a stipulated judgment. Adrian, 178 So.3d 297. Accordingly, we apply the manifest error standard of review.

The court in Adams, 382 So.3d at 234–35 (alterations in original), explained the manifest error standard of review:

“[A] reviewing court may not merely decide if it would have found the facts of the case differently.” Hall v. Folger Coffee Co., 03-1734, p. 9 (La. 4/14/04), 874 So. 2d 90, 98. Rather, “one of the basic tenets of the manifest error standard of review is that ‘reasonable evaluations of credibility and reasonable inferences of fact should not be disturbed upon review, even though the court of appeal is convinced that had it been the trier of fact, it would have weighed the evidence differently.’ ” Id., 03-1734, pp. 10-11, 874 So. 2d at 99 (quoting Parish Nat. Bank v. Ott, 02-1562, p. 7 (La. 2/25/03), 841 So. 2d 749, 753). The Louisiana Supreme Court pronounced a two-prong test for reversing factual findings. First, “[t]he appellate court must find from the record that a reasonable factual basis does not exist for the finding of the trial court.” Stobart v. State through Dep't of Transp. & Dev., 617 So. 2d 880, 882 (La. 1993). Second, “the appellate court must further determine that the record establishes that the finding is clearly wrong (manifestly erroneous).” Id.

b. The Law on Compromise

Louisiana Civil Code Article 3071 defines a compromise as “a contract whereby the parties, through concessions made by one or more of them, settle a dispute or an uncertainty concerning an obligation or other legal relationship.” Compromise agreements are favored by law, and “[c]ourts will not declare a settlement void without a clear showing that it violates good morals or public interest.” Adams v. Adams, 529 So.2d 877, 879 (La.App. 4 Cir.), writ denied, 533 So.2d 363 (La.1988). In Adams, the fourth circuit held that when Mrs. Adams waived her right to permanent alimony in a consent judgment, she was bound by such. The court noted that compromise settlements should not be “invalidated lightly[,]” and ruled that she could not re-litigate the alimony issue:

It is the public policy of our judicial system to provide an unalterable method to terminate litigation. The Louisiana Supreme Court has consistently held that legally confected in-court judicial settlements are binding. Collins v. Capital Valve and Fitting Co., 409 So.2d 579 (La.1982); Felder v. Georgia Pacific Corp., 405 So.2d 521 (La.1981). Therefore, as a matter of public policy, Mrs. Adams’ court confected compromise prevents her from relitigating the alimony issue.

Id.

c. The Merits

The issue before us is narrow: whether the provisions in the 2016 Stipulated Judgment requiring Stoney to pay Amanda's health insurance and gas expenses constitute spousal support pursuant to La.Civ.Code art. 111 et seq.

Though the question before us is a narrow one, we nevertheless first consider whether the 2017 Stipulated Judgment nullified or modified portions of the 2016 Stipulated Judgment. As stated above, the 2016 Stipulated Judgment required Amanda to pay for maintenance and insurance on the Jeep and the Cadillac; however, it expressly provided that Stoney would be responsible for the gas expenses for those vehicles, plus “for any other vehicles” used by Amanda. The 2017 Stipulated Judgment reiterated that Amanda was responsible for “[a]ny and all debts associated with the” Jeep and the Cadillac, “including but not limited to the monthly note, maintenance and insurance[.]” It also held that Amanda assumed “[a]ny and all liabilities incurred by her since September 22, 2016[.]” However, whereas the 2016 Stipulated Judgment explicitly referenced gas expenses, the 2017 Stipulated Judgment was silent regarding Amanda's gas expenses. It was also silent regarding Amanda's health insurance.

Our careful review of the record shows that the 2017 Stipulated Judgment complemented the 2016 Stipulated Judgment rather than nullified or modified it. The plain language of the 2016 Stipulated Judgment shows that the parties identified “gas expenses” as something distinct and separate from maintenance. Had the parties intended to change the provision of the 2016 Stipulated Judgment obligating Stoney to pay Amanda's gas expenses, they could have done so in the 2017 Stipulated Judgment. Yet, they did not.

We also find it significant that the 2016 Stipulated Judgment held Stoney responsible for Amanda's gas expenses for not only the Jeep and Cadillac, but also “for any other vehicles” used by Amanda. The inclusion of “any other vehicles” evidences the parties’ intent for Stoney to pay Amanda's gas expenses beyond the life of the Jeep and the Cadillac. We further note that the parties confirmed the 2016 Stipulated Judgment when Stoney continued paying Amanda's health insurance and gas expenses well beyond the effective date of the 2017 Stipulated Judgment. Stoney paid Amanda's health insurance until March 16, 2021, and her gas expenses until September 6, 2022—three days after Amanda remarried. “When a contract is ratified through the subsequent actions of the parties, that contract is confirmed by that ratification.” Rowan v. Town of Arnaudville, 02-882, p. 7 (La.App. 3 Cir. 12/11/02), 832 So.2d 1185, 1190.

While the 2017 Stipulated Judgment contains a provision holding Amanda responsible for liabilities incurred by her since September 22, 2016, such must be read in conjunction with the 2016 Stipulated Judgment. Under La.Civ.Code art. 2050, contractual provisions “must be interpreted in light of the other provisions so that each is given the meaning suggested by the contract as a whole.” Similarly, contractual provisions across multiple agreements should also be given legal effect when possible. If “liabilities” included health insurance and gas expenses, then the 2016 Stipulated Judgment would be meaningless, as it was filed on November 2, 2016. Absent an explicit reference in the 2017 Stipulated Judgment of an intent to modify the gas expense or health insurance provisions in the 2016 Stipulated Judgment, we do not find that a modification occurred.

Now we consider the merits of Stoney's assignment of error. He argues that the obligations are alimentary obligations of permanent periodic support. Although the stipulation does not characterize these obligations as spousal support, he contends that they are maintenance expenses involving the “basic necessities of life[,]” and therefore, indicative of spousal support. He also asserts that any doubt or ambiguity must be interpreted against Amanda and in his favor since her attorney drafted the contract. Amanda argues that the 2016 Stipulated Judgment is contractual in nature, with clear and unambiguous language, contains no reference to spousal support or maintenance payments, and includes a provision acknowledging that Stoney voluntarily and freely entered into the agreement after the divorce judgment was rendered, fully understood the terms, and was advised to obtain counsel.

Louisiana Civil Code Articles 111-16 establishes the scope and characteristics of spousal support. Under La.Civ.Code art. 111, entitled, “Spousal support; authority of court,” “the court may award interim periodic support to a party or may award final periodic support to a party who is in need of support and who is free from fault prior to the filing of a proceeding to terminate the marriage in accordance with the following Articles.” Louisiana Civil Code Article 112 specifies when a spouse may be awarded interim spousal support or final periodic support and requires the court to consider several relevant factors. Under La.Civ.Code art. 115, final periodic support is extinguished when the obligee remarries, either party dies, or there is a judicial determination of cohabitation.

These articles plainly and unambiguously contemplate court-awarded periodic support, not obligations negotiated between the parties. See La.Civ.Code art. 9 (“When a law is clear and unambiguous and its application does not lead to absurd consequences, the law shall be applied as written and no further interpretation may be made in search of the intent of the legislature.”). Absent a court's award of spousal support, these articles, including La.Civ.Code art. 115, do not apply. By contrast, the judgment at issue is a consent judgment, “a bilateral contract which is voluntarily signed by the parties and accepted by the court.” Durfee v. Durfee, 44,281, p. 4 (La.App. 2 Cir. 5/13/09), 12 So.3d 984, 988. Such a judgment derives its binding effect from the parties’ consent, not from the court's adjudication. Id. Accordingly, applying the Civil Code's spousal support articles to a stipulated judgment reached by agreement between the parties, without any indication that the parties intended to be governed by those articles, constitutes a departure from the law.

The jurisprudence supports this interpretation. In Shannon v. Shannon, 24-140 (La.App. 4 Cir. 10/25/24), 400 So.3d 334, the fourth circuit held that the parties’ consent judgment, which required Mr. Shannon to pay Ms. Shannon spousal support even upon her remarriage, could not be terminated. The court recognized the “crossroads between default Civil Code articles and the presence of a consent judgment[,]” and held that the terms of the contractual provisions in the consent judgment prevailed over the default rules of the Civil Code regarding termination of spousal support. Id. at 346.

In Aufrichtig v. Aufrichtig, 34,909 (La.App. 2 Cir. 8/22/01), 796 So.2d 57, the second circuit upheld provisions of a post-divorce agreement requiring continued alimony and health insurance coverage, rejecting the argument that they violated public policy. The court explained that post-divorce agreements are “enforceable according to their own terms or the proven intent of the parties.” Id. at 62.

In Murrell v. Murrell, 42,070 (La.App. 2 Cir. 4/25/07), 956 So.2d 697, the second circuit held that Mr. Murrell's contractual obligation to maintain health insurance coverage for his former wife was not periodic support subject to modification under La.Civ.Code art. 114. The court noted that health insurance is included within the definition of maintenance. However, because the obligation arose from a negotiated partition agreement rather than a judicial award of support, it was governed by general contract principles rather than the Civil Code provisions applicable to spousal support awards.

These cases recognize that maintenance expenses, while frequently included as part of a spousal support award, are not necessarily themselves spousal support. The terms of contractual provisions in a consent judgment prevail over the default rules of the Civil Code regarding termination of spousal support, even when an obligation is expressly labeled as spousal support. Shannon, 400 So.3d 334. Although Stoney relies on Williams v. Williams, 12-281 (La.App. 1 Cir. 11/14/12) (2012 WL 5506669) (unpublished opinion), where the first circuit affirmed the trial court's classification of a consent judgment's obligation to pay pension and health insurance premiums as spousal support subject to modification under La.Civ.Code art. 112 et seq., that decision appears to be an outlier. Furthermore, in so ruling, the Williams court held that “the intent of the parties’ agreement was to equalize their monthly income (a factor considered in the determination of spousal support), not to partition or equally divide that asset.” Id. at p. 7. This is factually distinguishable from the present case, where there was no evidence of income equalization.

Applying the manifest error standard of review, we cannot say that the trial court was clearly wrong in interpreting the disputed provisions as contractual obligations rather than spousal support, especially in light of the plain language of the 2016 Stipulated Judgment and the jurisprudence recognizing that consent judgments are generally not governed by the Civil Code articles on spousal support. The parties bargained and freely entered into the 2016 Stipulated Judgment, and nothing in the record suggests that the disputed provisions were intended to be spousal support terminable upon Amanda's remarriage. Although the payment obligations contain no explicit termination date, our review is limited to the issues raised in Stoney's appeal, i.e., whether the provisions constitute spousal support. As one court aptly observed, “a compromise may not be rescinded because it is later determined that the bargain struck was a poor one.” Hymel v. Eagle, Inc., 08-1287, p. 10 (La.App. 4 Cir. 3/18/09), 7 So.3d 1249, 1256, writ denied, 09-873 (La. 5/15/09), 8 So.3d 590. Likewise, “[c]ompromise settlements are not invalidated lightly[,]” and public policy favors their enforcement. Adams, 529 So.2d at 879. Accordingly, we find no manifest error and, thereby, affirm the trial court's denial of Stoney's Petition to Terminate Interim Period Spousal Support.

As to Stoney's second argument regarding Amanda's remarriage, this assignment of error presupposes that the obligations are spousal support obligations subject to La.Civ.Code art. 115. Since we affirm the trial court's ruling that the obligations at issue are not spousal support obligations subject to La.Civ.Code art. 115, this assignment of error is moot.

DECREE

For the foregoing reasons, we affirm the trial court's judgment. Costs of this appeal are assessed equally between Amanda Malone Courville and Stoney James Courville.

AFFIRMED.

FOOTNOTES

1.   Amanda Malone Courville is now known as Lucy Amanda Monceaux. We will refer to her as “Amanda” throughout the opinion.

2.   Amanda later filed a Motion and Order for Partial Dismissal, asking that her Motion to Rescind Partition for Lesion be dismissed, which was granted by the court.

3.   The parties timely filed appeals in July 2025, following the trial court's June 27, 2025 Written Reasons and Judgment. On August 1, 2025, the trial court filed this Partial Final Judgment.

4.   The trial court did not expressly state that the Quit Claim Deed modified the 2017 Stipulated Judgment. However, although it did not use the term “modify,” our review of the Written Reasons and Judgment demonstrates that the court effectively concluded that such a modification occurred.

5.   There are exceptions to this general rule; however, the only relevant exception for purposes of this appeal is simulation, which we address in the following section.

6.   Consideration is a common law concept. Louisiana instead uses the broader civil law concept of cause. As the first circuit has explained:Louisiana does not follow the common law tradition that requires consideration to effect an enforceable contract. Rather, the mere will of the parties will bind them, without what a common law court would consider to be consideration to support a contract, so long as the parties have a lawful “cause.” The cause need not have any economic value. Sound/City Recording Corp. v. Solberg, 443 F.Supp. 1374, 1380 (D.C.La.1978).Unlike the common law analysis of a contract using consideration, which requires something in exchange, the civil law concept of “cause” can obligate a person by his will only. The difference has been analogized to a civilian contract-consent approach compared to a common law contract-bargain approach. Consideration is an objective element required to form a contract, whereas cause is a more subjective element that goes to the intentions of the parties.Aaron & Turner, L.L.C. v. Perret, 07-1701, pp. 7-8 (La.App. 1 Cir. 5/4/09), 22 So.3d 910, 915, writ denied, 09-1148 (La. 10/16/09), 19 So.3d 476.