Christine M. Starrett v. Irven G. Starrett, 101 A.3d 435

Christine and Irven Starrett married in 1980, separated in 2010, and Christine filed for divorce in 2010; two adult children not at issue.
The central asset dispute concerned Irv’s Drywall, a closely held corporation founded by Irven during the marriage; business declined after the economic downturn.
Parties jointly retained an appraiser who valued the business at approximately $392,000 as of March 31, 2012; Christine urged at least $450,000, Irven said he would sell for $200,000.
The District Court rejected the appraiser’s opinion and Christine’s higher estimate, concluded the business had no realistic sale value and that its primary value was Irven’s ability to earn income through it, and awarded the business and its debt to Irven.
The court found Christine capable of earning $50,000/year and Irven $93,000/year; it awarded Christine spousal support ($1,000/month until sale of residence, then $2,000/month), and required Irven to pay mortgages (~$5,200/month) until sale.
On appeal Christine argued error in valuation (liquidation value), income findings, and sale provisions; the Supreme Judicial Court affirmed, finding a small arithmetic error in the court’s liquidation calc but no prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Valuation of Irv’s Drywall	Christine: court undervalued business; appraiser’s $392k or her $450k should be credited	Irven: business lacks realistic market value; primary value is his labor/income stream	Court may reject appraiser and parties’ estimates; finding of no realistic market sale value upheld despite clerical liquidation error
Liquidation calculation error	Christine: court erred factually — debts exceed assets	Irven: any arithmetic error is immaterial to distribution	Court found liquidated net value was actually +$47,039 but deemed error harmless — no prejudice
Property distribution (award of business to Irven)	Christine: losing any positive liquidation share prejudiced division	Irven: awarding business to him, with debts and mortgage/spousal obligations, fairly allocates income source and liabilities	Court’s overall property division affirmed as not an abuse of discretion
Income and spousal support findings	Christine: was disabled and less able to earn; support should differ	Irven: Christine can earn ~$50k; he can earn ~$93k from business; support structured accordingly	Court’s credibility and earning-capacity findings supported by record; spousal support award affirmed

Bond v. Bond, 17 A.3d 1219 (Maine 2011) (standard of review for factual findings and property division in divorce)
Wandishin v. Wandishin, 976 A.2d 949 (Maine 2009) (trial court may evaluate and reject valuation evidence and expert testimony)
St. Hilaire v. St. Hilaire, 526 A.2d 28 (Me. 1987) (trial court discretion to authorize a party to facilitate sale of marital real estate)
In re Joshua B., 776 A.2d 1240 (Maine 2001) (prejudice requirement when claiming trial error under harmless-error principles)