Expressly

“In direct or unmistakable terms;” “directly and distinctly stated; expressed, not merely implied or left to inference.” This is how the term was defined in In re Estelle’s Estate, 122 Ariz. 109 (App. 1979). Where something must be expressly stated in writing, there should be no mistaking its meaning. Such was the case in Estelle where Wife argued that Husband’s spousal maintenance obligation to her survived his death “by implication.” The Court of Appeals disagreed, noting that ARS 25-327 requires that for a spousal maintenance obligation to continue past one’s death, it must be expressly stated yet the Decree made no mention of it lasting beyond Wife’s death. Therefore, her request was denied.