Thieme v. Aucoin-Thieme
Supreme Court of New Jersey
151 A.3d 545 (2016)
Michael Thieme (plaintiff) and Bernice Aucoin-Thieme (defendant) lived together for eight years and were married for only 14 months before divorcing; during their cohabitation, Thieme worked long hours at International Biometrics Group (IBG) while Aucoin-Thieme cared for their child, with the couple jointly planning around IBG's promise of substantial deferred compensation to Thieme if the company was later sold, even though he held no ownership stake. IBG sold three months after the divorce was finalized, paying Thieme a $2.25 million closing bonus; Aucoin-Thieme moved for a share, and the trial court awarded her an equitable distribution limited to the portion of the bonus Thieme earned during their brief 14-month marriage, which the appellate court affirmed.
Whether, in a divorce proceeding, a court can award a constructive trust based on equitable principles to avoid unjust enrichment from property obtained prior to marriage but during cohabitation.