511 P.3d 1253
Utah Ct. App.2022Background
- Vicki and Randall Beckham divorced after a bench trial during which the parties disputed treatment of two term life insurance policies on Randall’s life.
- The parties did not provide the actual policies to the district court; the court found it unclear whether the policies were renewable, had cash value, or terminated on divorce.
- Vicki sought to be named a beneficiary of one policy; the court denied that request and left beneficiary control with Randall.
- The court nevertheless characterized the policies as marital assets and found both parties had paid premiums; it ordered Randall to reimburse Vicki $40,000 for premiums she paid over eight years.
- Both parties had argued the policy had no cash value and that any value was contingent on Randall’s death; the record lacked evidence that the policy retained value after paid coverage periods lapsed.
- Randall appealed the reimbursement award; the Court of Appeals reversed, concluding the premiums were consumed during the marriage and Vicki had already received their benefit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly ordered Randall to reimburse Vicki for life-insurance premiums paid during the marriage | Vicki: she paid premiums for a marital asset that remains with Randall and is entitled to reimbursement | Randall: the policy had no cash value; premiums purchased coverage consumed during the marriage, so no post-divorce enrichment to reimburse | Reversed: premiums were consumed as marital living expenses/insurance coverage and Vicki already received their benefit, so reimbursement was improper |
Key Cases Cited
- Johnson v. Johnson, 330 P.3d 704 (Utah 2014) (standard of review and presumption of validity for district court property divisions)
- Collard v. Nagle Constr., Inc., 149 P.3d 348 (Utah 2006) (abuse-of-discretion review for equitable remedies)
- Kartchner v. Kartchner, 334 P.3d 1 (Utah Ct. App. 2014) (review principles for equitable division)
- Mortensen v. Mortensen, 760 P.2d 304 (Utah 1988) (treatment of consumed marital property in equitable division)
- Argyle v. Argyle, 688 P.2d 468 (Utah 1984) (burden to offer evidence on alternative valuation methods)
- In re Marriage of Rolfe, 699 P.2d 79 (Mont. 1985) (consumed property not subject to reimbursement)
- In re Marriage of Burwell, 164 Cal. Rptr. 3d 702 (Cal. Ct. App. 2013) (discussion of term-policy premiums creating time-limited coverage interests)