Heck, P. v. Valentin, D.
796 EDA 2017
| Pa. Super. Ct. | Oct 24, 2017Background
- Parties lived in a common-law marriage from 1997 and separated in 2012; one emancipated child. Wife is disabled (rheumatoid arthritis) with modest pension and SSDI; Husband is a PA State Trooper earning about $97,477/year.
- Special Master found marital estate of $428,034 and recommended a 60%/40% split (Wife $256,820; Husband $171,214), which translated into a $231,813 lump-sum payment from Husband to Wife (60% share adjusted for other distributions and fees).
- Special Master also recommended alimony of $1,094/month for three years; Husband had already paid spousal support for over four years pre-decree.
- Husband owned a collection of non-running/restoration Camaros; Special Master valued two (1967 and 1969 Pace Car) higher than Husband’s $15,000 estimates based on purchase and parts expenditures.
- Trial court adopted the Special Master’s recommendations, including the 90-day, interest-free requirement that Husband pay the $231,813 lump sum, and limited alimony to three years; both parties filed exceptions and appealed (cross-appeals).
Issues
| Issue | Plaintiff's Argument (Heck) | Defendant's Argument (Valentin) | Held |
|---|---|---|---|
| Whether three-year alimony award was insufficient | Wife: Disabled and unlikely to work; needs indefinite alimony until she receives pension or lump-sum equitable distribution | Husband: Not directly contesting duration beyond arguing overall distribution suffices | Court: Affirmed three-year alimony — not an abuse of discretion given lump-sum award, enforcement remedies, prior support paid, and overall economic justice |
| Whether valuation of 1967 and 1969 Camaros was erroneous | Wife: Valuations were reasonable given Husband’s expenditures, prior asking price, and credibility findings | Husband: Valuations inconsistent with other Camaros and NADA; cars are disassembled parts; values should be $15,000 each | Court: Affirmed valuations — master reasonably credited parts and expenditures and weighed credibility; trial court did not abuse discretion |
| Whether ordering Husband to pay $231,813 in cash within 90 days was punitive/unreasonable | Wife: (argued payment supports her needs) | Husband: Lacks liquidity; 90-day cash requirement is punitive given his obligations | Court: Affirmed 90-day payment requirement — husband has substantial income, spent marital funds on hobby, and could liquidate assets; trial court’s order not abusive |
Key Cases Cited
- Teodorski v. Teodorski, 857 A.2d 194 (Pa. Super. 2004) (purpose and factors for alimony awards)
- Anderson v. Anderson, 822 A.2d 824 (Pa. Super. 2003) (factors to determine alimony nature/amount/duration)
- Williams v. Williams, 540 A.2d 563 (Pa. Super. 1988) (upholding alimony contingent on receipt of other assets in certain circumstances)
- Carney v. Carney, 167 A.3d 127 (Pa. Super. 2017) (standard of review for equitable distribution and deference to masters on credibility)
- Mundy v. Mundy, 151 A.3d 230 (Pa. Super. 2016) (no specific valuation method required; trial court discretion)
- Smith v. Smith, 904 A.2d 15 (Pa. Super. 2006) (trial court may rely on estimates, inventories, purchase records when valuing assets)