In re Marriage of Brown (1995) 35 Cal.App.4th 785
Holding
Trial court may not extend spousal support where the judgment based on the parties’ agreement “expressly terminates the court’s jurisdiction to do so.” Explicit termination language is required to oust the court of post-deadline jurisdiction. Before expiration of the support period, the court retains jurisdiction to extend the support term unless the agreement / judgment specifically provides otherwise.
Relevance to this matter
Cited by name in Stipulated Judgment ¶62 and ¶63. The parties’ express ¶62 / ¶63 waivers are the precise kind of explicit termination language Brown contemplates. Together with In re Marriage of Vomacka and In re Marriage of Ousterman, it forms the trio of cases the parties contracted around. The Vomacka / Brown / Ousterman waivers eliminate any path to extend Jennifer’s spousal support obligation past 1/31/2025.