Araya v. Keleta
65 A.3d 40
| D.C. | 2013Background
- Married 2004, separated 2009; three minor daughters at divorce.
- Trial court awarded wife sole physical custody to be with children and ordered husband to pay child support.
- Court awarded wife two properties (1800 New Jersey Ave NW and 435 S Street NW) as sole and separate initially.
- Court also awarded wife $6,000 monthly alimony for 24 months to enable training for employment.
- Trial court treated two adjacent properties as a single marital asset due to integration and renovations by husband.
- Consolidated appeals challenged custody, support, alimony, property distribution, and attorney’s fees; only the property-distribution ruling regarding real property brought a published opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether New Jersey Avenue and S Street are marital property | Araya contends both properties remained sole and separate | Keleta contends the properties became marital through transmutation | Yes; two properties transformed into marital property under §16-910(b) based on integration and family use |
| Whether the S Street property was acquired with marital funds | Araya claims funds traceable to pre-marital sale | Keleta argues funds may be traceable and thus marital | Marital funds; S Street found part of marital estate and distributable |
| Whether the New Jersey Avenue property remained separate property | Araya argues it was sole and separate pre-marital property | Keleta argues transformation via commingling and family use | Transformed by mingling with S Street; became part of marital property under Darling and related doctrine |
| Whether the property distribution supports alimony award and other relief | Araya asserts misapplication of factors and value | Keleta argues proper application of §16-910(b) factors and need-based alimony | Distribution and alimony affirm; court’s factual findings within discretion |
Key Cases Cited
- Darling v. Darling, 444 A.2d 20 (D.C. 1982) (transformation of separate property into marital asset under §16-910(b))
- Ealey v. Ealey, 596 A.2d 43 (D.C. 1991) (equitable lien for substantial contribution to separate property)
- Yeldell v. Yeldell, 551 A.2d 832 (D.C. 1988) (transformation through family use and contributions; inception of title concept nuances)
- Sanders v. Sanders, 602 A.2d 663 (D.C.1992) (home as separate property; homemaker contributions may create equitable interest)
- Brice v. Brice, 411 A.2d 340 (D.C.1980) (disproportionate payments may create equitable interest in home)
- Leibel v. Leibel, 190 A.2d 821 (D.C.1963) (trials may impute income; discretion in support)
- Mumma v. Mumma, 280 A.2d 73 (D.C.1971) (income imputation and alimony/support discretion)
- Cefaratti v. Cefaratti, 315 A.2d 142 (D.C.1974) (scope of trial court discretion in support)
- Jordan v. Jordan, 14 A.3d 1136 (D.C.2011) (manifest abuse of discretion standard in custody)
- Araya v. Keleta, 19 A.3d 358 (D.C.2011) (precedential guidance on custody and intrafamily offenses; CPOs not dispositive)