Glanden v. Quirk, 128 A.3d 994

Husband and Wife separated in September 2012 after 22 years of marriage; divorce finalized in 2013.
Family Court allocated 65% of non-retirement assets to Wife and split remaining assets, including retirement assets, equally; alimony awarded to Wife for an indefinite period.
A $2.7 million January 2013 payment from Husband’s law firm was credited as earned in 2012, partially increasing the marital estate.
Husband earned over $3 million annually; Wife was homemaker who later pursued a $40,000-per-year job with potential bonuses.
Court considered living standard, earning potential, and investments in calculating alimony and security provisions, including life insurance for Wife.
On appeal, Husband challenges the interpretation of the January payment as marital property, the property division, alimony, asset valuation for investment income, and the rate of return used.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the January 2013 payment was marital property.	Husband argues the payment, received after separation, isn’t marital property.	Wife contends part of the payment was earned during the marriage and thus marital.	Partially marital; earned in 2012, so includable.
Whether the 65%/50% division of assets was an abuse of discretion.	Husband asserts improper weighing of factors under 13 Del. C. § 1513(a).	Wife contends the court properly weighed factors and divisions were supported by evidence.	No abuse of discretion; division affirmed.
Whether Wife’s dependency and alimony award were proper given asset allocation.	Wife’s assets should not affect dependency if Husband can pay.	Assets and standard of living justify dependency and alimony.	Court did not abuse discretion; Wife deemed dependent and awarded alimony.
Whether excluding the cost of housing from Wife’s investable assets was proper for alimony calculations.	Excluding housing costs artificially inflates investable assets.	Allocation decisions considered relevant factors and assets.	Not an abuse of discretion; decision affirmed.
Whether the 4.5% rate of return on investments was reasonable.	Husband argues the rate is too low/high based on expert ranges.	Court used middle ground between experts; within range.	Not clearly wrong; 4.5% upheld.

Roberts v. Roberts, 19 A.3d 277 (Del. 2011) (standard for reviewing family court property and alimony determinations)
Thomas v. Thomas, 102 A.3d 1138 (Del. 2014) (dependency and alimony considerations in high-standard-of-living cases)
Lorillard Tobacco Co. v. Am. Legacy Found., 903 A.2d 728 (Del. 2006) (interpretation of contracts and evidentiary considerations in court rulings)