Degnan v. Degnan, 877 N.W.2d 38

Barbara (55) and Lowell Degnan (65) married in 2009 and divorced in 2015; marriage lasted ~5 years.
Barbara received about $750/month SSDI (net) and had monthly expenses ≈ $2,200; Lowell received railroad retirement ≈ $3,471 net with expenses ≈ $2,265 and substantial savings.
At trial a witness, Tammy Shiek, testified (over objection) that Barbara discussed marrying Lowell for financial benefits (insurance, income).
District court awarded Barbara limited temporary spousal support ($180/month for 60 months), certain vehicles, a camper, $3,000 in attorneys fees initially and later $5,000 (offset by $2,000 interim payment); majority of marital assets went to Lowell.
Barbara moved for amended findings and a new trial; district court denied. Barbara appealed; Lowell sought appellate attorney fees as frivolous.

Issue	Plaintiff's Argument (Degnan)	Defendant's Argument (Lowell)	Held
Admissibility of pre-marriage testimony about motive	Testimony was irrelevant and prejudicial; should be excluded.	Testimony was relevant to Barbara’s financial circumstances and motive, bearing on equitable division/support.	Admission was within trial court’s discretion; relevant to financial circumstances and conduct and not an abuse of discretion.
Use of motive testimony in Ruff–Fischer analysis	Motive to marry is not a Ruff–Fischer factor and should not influence property/support awards.	Court may consider conduct and other material matters; motive is material here.	Court may consider conduct and other material matters; motive was material and findings were not clearly erroneous.
Property division equity	Award (≈ $15,685 to Barbara of $209,020 total) was inequitable; should be more equal.	Short marriage; parties keep what they brought in; Lowell accumulated most assets pre-marriage.	Unequal division permissible in short-term marriage; court’s division not clearly erroneous.
Spousal support amount/duration	Award insufficient given Barbara’s needs and inability to work.	Limited, rehabilitative/temporary support appropriate given short marriage and assets.	Temporary support appropriate; $180/mo for 60 months was not clearly erroneous.

Beck v. Lind, 235 N.W.2d 239 (irrelevance test for evidence)
Ruff v. Ruff, 52 N.W.2d 107 (Ruff–Fischer factors framework)
Fischer v. Fischer, 139 N.W.2d 845 (conduct and other material matters may be considered)
Hoverson v. Hoverson, 828 N.W.2d 510 (application of Ruff–Fischer factors)
Pearson v. Pearson, 771 N.W.2d 288 (standard for reviewing spousal support findings)
Jondahl v. Jondahl, 344 N.W.2d 63 (factors for awarding attorney’s fees in divorce)