Cited by

Sommers v. Sommers, 143 N.H. 686, 689 (1999) (describing limited circumstances in which the trial court may modify a final property division in a divorce).

The respondent contends that this amounted to an improper modification of a final property settlement.

We consider the intent of the parties as expressed in the language of the stipulation.

The trial court may not modify a property distribution in a final divorce decree absent certain limited circumstances that are not at issue here.

Implementation of the terms of a stipulation, however, does not constitute the modification of a property settlement.

The petitioners’ “burden of proof in a reformation action is a heavy one.” Sommers v. Sommers, 143 N.H. 686, 690 (1999) (quotation omitted).

State v. Schmidt, 957 A.2d 80, 87 (Me. 2008) (vacating theft by unauthorized taking or transfer convictions because victims — unpaid subcontractors and suppliers — 5 “had only a right to repayment that could afford them a security interest in the form of a mechanic’s lien on the property”); Sommers v. Sommers, 143 N.H. 686, 692 (1999) (finding language of stipulation in divorce decree awarding automobile to defendant but conditioning transfer of title on defendant’s payment of debt and taxes pro

“The plaintiff’s burden of proof in a reformation action is a heavy one.” Sommers v. Sommers, 143 N.H. 686, 690 (1999) (quotation omitted).

Accordingly, we look to the terms of the final decree to determine whether the court “specified differently.” *108 In interpreting the meaning of a divorce decree, we review the decree de novo.

The petitioner’s burden of proof in a reformation action is a heavy one.

He contends that by so doing, the trial court modified the parties’ property settlement absent the requisite finding of fraud, undue influence, deceit, misrepresentation or mutual mistake.

In interpreting the meaning of a divorce decree, we review the decree de novo.

“A property settlement in a divorce decree is a final distribution of a sum of money or a specific portion of the spouses’ property and is not subject to judicial modification on account of changed circumstances.” Sommers v. Sommers, 143 N.H. 686, 689 (1999).

“Findings of fact by a trial court are binding on us unless they are not supported by the evidence or are erroneous as a matter of law.” Sommers v. Sommers, 143 N.H. 686, 690, 742 A.2d 94, 97 (1999) (quotation omitted).