Cited by

In exercising its discretion, however, a court must be mindful of the “compelling interest in the finality of judgments which should not be lightly disregarded.” (citation modified); ¶ 11 (1999) (“A judgment is a solemn record[,]” and “[i]t should not lightly be disturbed.” (citation omitted)).

A decree is “an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.” ¶ 11 (1999).

¶ 10 (1999) (“[I]t is error to conclude that the parol evidence rule applies to judgments,” because “[a] judgment is not an agreement between or among the parties.”).

¶ 11 (1999) (“[A]pplying the parol evidence rule to a judgment would create a result contrary to the very rationale for a judgment.”).

¶¶ 9–12 (1999) (because parol evidence rule does not apply to judgments, it cannot be applied to dissolution decrees); (stating that “‘incorporation’ and ‘merger’ are not synonymous” and addressing the legal consequences of each with respect to marital settlement agr

-50, ¶¶ 10-15 (1999) (noting that it was error to consider parol evidence to resolve a dispute about the duration of an award of spousal maintenance).

¶ 11 (App. 2007); -50, ¶¶ 13-15 (1999).

“A final judgment or decree is ‘an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.’” ¶ 10 (App. 2007) ( ¶ 11 (1999)).

¶ 11 (1999); see also Ariz. R. Civ.

§ 25-324 is “to provide a remedy for the party least able to pay.” ¶ 13 (App. 2007) ( ¶ 20 (1999)).

A final judgment “exists as an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.” ¶ 11 (1999).

¶9 Furthermore, any error in the admission of this evidence would be harmless because the superior court explained it would not consider the extrinsic evidence when interpreting the consent decree, -50, ¶¶ 10-11, 14 (1999) (stating a consent decree, as a final judgment, is “an independent resolution by the court of the issues before it” and applying the parol evidence rule constitutes an “impermissible collateral attack”), and, ultimately, rejected 4

Moreover, a properly-entered decree is not a contract but, rather, “an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.” ¶ 11 (1999).

¶8 Furthermore, our supreme court has held “the parol evidence rule, a rule of substantive contract law, does not apply to a judgment.” ¶ 15 (1999); (“[W]here a court has the general power to modify a decree for alimony or support, the exercise of that power is not affected by the fact that the decree is based on an agreement entered into by the parties to the action.”) (internal quota

CBS contends Cohen is contrary to In re Marriage of Zale, which held that “the parol evidence rule, a rule of substantive contract law, does not apply to a judgment.” ¶ 15 (1999).

A decree is “an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.’’ Cohen, 215 Ariz. at 66, ¶ 10, 157 P.3d at 486 ( ¶ 11, ).

The objective “is to provide a remedy for the party least able to pay.” ¶ 13, ( ¶ 20, ) (internal quotation marks omitted).

¶5 A consent decree is “an independent resolution by the court of the issues before it and rightfully is regarded in that context and not according to the negotiated intent of the parties.” ¶ 11, (citation omitted).