Huffaker v. Huffaker
2012 S.D. 81
| S.D. | 2012Background
- Huffaker v. Huffaker involves a 2011 divorce where Danielle received primary custody and Jeffrey was ordered to pay $1,310 monthly child support.
- The trial court did not value marital property before distributing it and awarded assets resulting in ~90/10 split in Jeffrey’s favor.
- Disputed asset values included the 1994 Pontiac Firebird, 2005 BMW Mini Cooper, and Jeffrey’s 50% retirement share plus the $30,000 Career Status Bonus.
- Jeffrey spent the $30,000 Career Status Bonus on various debts and personal expenses; the court’s findings on this were inconsistent.
- Danielle appealed alleging improper property valuation, inequitable distribution, failure to award arrearages, and denial of attorney fees.
- The appellate court remands on valuation and distribution issues, and affirms denial of arrearages under SDCL 25-7-6.1, while directing reconsideration of attorney fees on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court failed to value marital property before distribution | Huffaker argues court did not assign values and relied on conjecture | Huffaker contends distribution did not require precise values at the time | Abuse of discretion; remand for valuation and redistribution |
| Whether the property division was equitable in light of missing valuations | Huffaker asserts disparity (90/10) without factor-based justification | Huffaker contends equitable distribution given circumstances | Abuse of discretion; remand to apply distribution factors and proper valuations |
| Whether the trial court erred by not awarding child-support arrearages | Huffaker claims SDCL 25-7-6.1 supports arrears from Jan 2010 to Oct 2011 | Huffaker argues continued absence not met; no arrearages | Not an error; arrearages not awarded under the statute |
| Whether the court abused by denying Danielle's attorney-fee request | Huffaker sought two-step attorney-fee analysis | Huffaker’s request was denied without explanation | Remand for two-step attorney-fee analysis on remand |
Key Cases Cited
- Endres v. Endres, 532 N.W.2d 65 (S.D. 1995) (requires value and equitable distribution of marital property)
- Guthmiller v. Guthmiller, 670 N.W.2d 516 (S.D. 2003) (value-based distribution guidance)
- Farlee v. Farlee, 812 N.W.2d 501 (S.D. 2012) (value and range of values; abuse if not valued)
- Grode v. Grode, 543 N.W.2d 795 (S.D. 1996) (factors for division of property)
- Herrboldt v. Herrboldt, 303 N.W.2d 571 (S.D. 1981) (property division factors and equity)