When a divorce is finalized in Washington, the dissolution decree assigns specific debts and obligations to each spouse. But life does not stop at the decree. Cars break down, financial circumstances shift, and ex-spouses sometimes make informal arrangements to address new realities. The problem is that these side agreements can fundamentally change who owes what—and if something unexpected happens, the spouse who relied on an informal deal may end up with nothing to enforce. A recent Washington Court of Appeals decision, In re Marriage of Hoffner, No. 60680-1-II (Wash. Ct. App. Feb. 18, 2026), illustrates exactly how this plays out. If you are going through a divorce or dealing with enforcement of a decree in the Seattle area, the family law attorneys at Blair & Kim can help you protect your rights at every stage.
What Happened in the Hoffner Case?
The Hoffners’ divorce decree, based on a CR 2A agreement, required the husband to pay off a specific bank account debt—an Alaska account with a balance of approximately $57,600—that was connected to the wife’s car. The decree contemplated that proceeds from the sale of the marital home would cover this debt, but the home sold for less than expected, leaving about $27,000 still owed on the account. The husband agreed to pay the remaining balance in installments.
Then the wife’s car developed mechanical problems. The parties made a side agreement: the wife would trade in her car, the husband would cosign on a replacement vehicle, and the husband would make monthly payments on the new car’s loan until he had paid off the approximately $19,000 still owed from the original decree obligation. The husband also paid the insurance on the replacement car.
Before the husband finished paying down that amount, the replacement car was totaled in an accident. Insurance paid off the remaining loan on the replacement vehicle in full. The wife asked the husband to cosign on yet another car and resume payments for the amount insurance had covered. The husband refused. The wife filed a motion to enforce the original divorce decree.
The trial court denied the motion, finding that the debt the wife was trying to enforce had been extinguished by the insurance payment. The Court of Appeals affirmed.
Why Did the Side Agreement Backfire?
The original decree required the husband to pay a specific debt in a specific account for a specific dollar amount. When the parties informally agreed to “transfer” that obligation to a replacement car’s loan, they effectively replaced the decree’s terms with a new arrangement. Once insurance satisfied the replacement car’s debt in full, there was no remaining obligation tied to the original account—and the court found nothing left to enforce under the decree.
The wife argued that this was unjust: if the husband had paid off the original debt on schedule, she would have had both a paid-off car and insurance proceeds after the accident. The court acknowledged this argument but found that the husband’s obligation under the decree was to pay a certain debt, not to ensure the wife’s continued possession of a vehicle. Because the debt was satisfied—even if by insurance rather than by the husband’s payments—there was nothing left to enforce.
Critically, the side agreement between the parties was not formally documented in a way that preserved the wife’s rights. The court noted that a “waiver” allowing installment payments existed but was not part of the appellate record, and no written agreement clearly defined what would happen if the replacement car was lost before the husband finished paying.
What Can You Learn from This Case?
The Hoffner decision reinforces several principles that anyone involved in a Washington divorce should understand.
A divorce decree is a specific, enforceable order. When a decree assigns a particular debt to one spouse, the obligation is tied to that specific debt—not to a general promise to keep paying indefinitely. If the parties informally agree to redirect the obligation to a different debt, the original decree obligation may no longer be enforceable once the substitute debt is satisfied, even if the method of satisfaction was not what either party expected.
Informal agreements can undermine your decree rights. Side deals made after a divorce—especially ones that are not in writing or not approved by the court—can create ambiguity about what the decree actually requires. In Hoffner, the wife’s willingness to let the husband redirect his payments to a different vehicle ultimately left her without a clear enforcement mechanism when circumstances changed.
Always get modifications in writing and, ideally, approved by the court. Washington courts have broad equitable powers in family law matters under In re Marriage of Morris, 176 Wn. App. 893 (2013), and In re Marriage of Farmer, 172 Wn.2d 616 (2011). But absent certain conditions justifying the reopening of a decree, the trial court lacks authority to modify its terms. If you need to change how a decree obligation is fulfilled, the safest approach is to formalize the change through a stipulated order or agreed modification filed with the court.
Insurance proceeds can extinguish a debt obligation. If a decree obligation has been redirected to a specific loan and a third party—such as an insurance company—pays that loan in full, the court may find that the obligation no longer exists. This is true even if the outcome leaves one spouse worse off than they would have been under the original arrangement.
How Can You Protect Yourself When Modifying Divorce Obligations?
If you and your ex-spouse need to change how a decree obligation is fulfilled—whether it involves debt payments, property transfers, or support arrangements—there are steps you can take to protect your interests under Washington law.
Put everything in writing. Any agreement to modify how a decree obligation is satisfied should be documented in a written agreement signed by both parties. The agreement should specifically address what happens if circumstances change—for example, what happens if a vehicle is totaled, a property is damaged, or a refinancing falls through.
File a stipulated modification with the court. A written side agreement between ex-spouses is better than a verbal understanding, but it is not as strong as a court-approved modification. Under Washington law, a dissolution decree can be modified by stipulation of the parties if filed with and approved by the court. This gives both parties an enforceable court order rather than a private contract.
Do not assume your original decree protects you after a side deal. As Hoffner demonstrates, once you agree to redirect a decree obligation to a different debt or arrangement, the original decree terms may no longer be enforceable. Your attorney should review any proposed changes before you agree to them.
Consider the insurance implications. If a decree obligation is tied to a specific asset—like a car loan—and that asset is insured, think about what happens if insurance pays off the loan. Will the other spouse argue that the obligation has been satisfied? A well-drafted modification should address this scenario explicitly and specify whether the paying spouse’s obligation is to the other spouse personally or only to the specific lender. That distinction can determine whether the obligation survives when the debt is paid by a third party.
Talk to a Seattle Family Law Attorney About Enforcing Your Divorce Decree
Divorce decrees are designed to provide certainty. Informal side agreements can erode that certainty and leave you without an enforceable right when you need it most. Whether you are trying to enforce the terms of an existing decree, considering a modification, or responding to your ex-spouse’s request to change an obligation, getting legal advice before acting is the best way to protect yourself.
Blair & Kim’s family law team handles divorce enforcement, decree modifications, and property disputes across King County, Pierce County, and Snohomish County. To discuss your case with an experienced Seattle family law attorney, call Blair & Kim at (206) 622-6562 or contact the firm online.