Lumpsum Spousal Support in a high income case

La France v. Saroli, 2026 ONSC 1783

This Ontario Superior Court decision is principally a high-income common-law spousal support case involving a relatively short relationship, an enormous disparity in wealth, disputed dates of cohabitation, and sharply conflicting credibility evidence. Louise La France sought spousal support and damages for unjust enrichment from Robert Saroli. Justice Centa ultimately awarded her $3 million in lump-sum spousal support, but dismissed her unjust enrichment claim and declined to grant a restraining/no-contact order. 

Core findings

1. The parties were common-law spouses.The Court found that the parties cohabited in a conjugal relationship from January 1, 2019 to August 23, 2023, exceeding the three-year requirement under s. 29 of Ontario’s Family Law Act. The Court applied a contextual approach to the Molodowich factors rather than treating them as a rigid checklist. 

A major feature of the judgment was credibility. Justice Centa generally accepted La France’s account because it was internally consistent and supported by extensive contemporaneous documentary evidence, while finding Saroli’s testimony unreliable and lacking credibility. This credibility determination substantially affected the findings regarding when the relationship began and ended.

2. La France was entitled to non-compensatory—but not compensatory—spousal support.The Court did not find that the relationship caused La France an economic disadvantage sufficient to justify compensatory support. Instead, entitlement arose primarily from need and the dramatic decline in her standard of living following separation. During the relationship, she enjoyed an exceptionally affluent lifestyle, including an $18-million residence, a Cayman Islands property worth more than $5 million, private-jet travel, and luxury vacations. Following separation, her standard of living dropped precipitously. 

Her pre-existing disability was also important. The Court held that although the relationship did not cause her disability, her inability to return to employment created a continuing need and supported non-compensatory support intended to cushion the economic consequences of relationship breakdown.

3. Saroli’s support income was extraordinarily high.The Court determined Saroli’s income for support purposes at approximately $63.69 million annually. Because this vastly exceeded the $350,000 ceiling under the Spousal Support Advisory Guidelines (SSAG), the Court emphasized that the SSAG formula could not simply be mechanically applied. Instead, an individualized, fact-specific assessment was necessary. 

The Court concluded that an appropriate periodic equivalent would be approximately:

$200,000/month × 3 years = $7.2 million nominal periodic support

However, the Court converted this to a lump sum. After accounting for tax consequences and discounting, the calculated lump-sum equivalent was approximately $3.254 million. Because La France had sought a maximum of $3 million, the Court awarded $3 million, payable within 30 days. 

Why a $3-million lump sum?

The lump-sum aspect is one of the more significant parts of the decision. The Court stressed that lump-sum support is not limited to exceptional cases and is permissible where it represents a fair means of implementing support rather than disguising property redistribution. Saroli plainly had the capacity to pay. 

There were also strong practical reasons to sever the parties’ financial relationship: it had been a relatively short relationship with no children, there was substantial animosity between the parties, and allegations of threatening and abusive behaviour had been made. A lump sum allowed the parties to terminate their ongoing financial connection. 

Unjust enrichment claim — dismissed

La France also sought compensation for domestic services and her involvement in the design and renovation of Saroli’s home. The Court accepted that she had provided services capable, in principle, of constituting an enrichment. But she provided no evidence quantifying their value. More importantly, the Court considered the very substantial benefits she herself received during the relationship. 

She contributed nothing toward the purchase price, renovations, property taxes or utilities of the Lakeshore residence and otherwise enjoyed an extraordinarily expensive lifestyle largely funded by Saroli. The Court concluded that the value of her contributions did not exceed—and was not remotely close to—the benefits she received. The unjust enrichment claim was therefore dismissed. 

Restraining order — denied

The requested mutual no-contact/non-harassment order was also refused. Despite the parties’ acrimonious history, they had not spoken for approximately two years and Saroli’s last email to La France had been in 2024. The Court was not satisfied that the statutory threshold for a restraining order had been established, although Justice Centa expressly cautioned Saroli against contacting La France in the future. 

Analysis and significance

The most important aspect of La France v. Saroli is that a relatively short common-law relationship can still generate a very substantial support obligation where the payor is extraordinarily wealthy and the recipient experiences a profound post-separation decline in standard of living. The judgment does not treat the relationship’s luxurious lifestyle as irrelevant simply because it was relatively brief.

Second, the case illustrates the importance of non-compensatory support as a distinct basis for entitlement. La France did not need to establish that she sacrificed a career for Saroli or that the relationship caused her disability. Her entitlement instead arose from need, dependency and the economic consequences of the breakdown of the relationship.

Third, the decision demonstrates the limited utility of mechanically applying the SSAG in ultra-high-income cases. Above the $350,000 ceiling, the Court retained considerable discretion and focused on the parties’ actual circumstances, relationship duration, lifestyle, means and needs rather than simply extrapolating the formula. 

Finally, the judgment is a strong reminder about documentary evidence and credibility in family litigation. Contemporaneous records were critical. Where the parties offered radically different narratives, the Court repeatedly preferred the version supported by objective evidence. That ultimately influenced the threshold question of whether there was even a qualifying common-law relationship and, consequently, whether jurisdiction to award support existed at all.

Bottom line: The Court found a roughly 4½-year common-law relationship, rejected compensatory entitlement but found strong non-compensatory entitlement, attributed $63.69 million in annual support income to Saroli, assessed support at roughly $200,000/month for three years, and converted that obligation into a final $3-million lump-sum award. The unjust enrichment and restraining-order claims failed. 

One small point worth flagging: the overview at the beginning of the reasons appears to state an end date of August 23, 2024, whereas the substantive analysis expressly finds that cohabitation ended August 23, 2023. The latter is the date the Court actually relies upon in determining the relationship and support entitlement. 

Conclusion:

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