Hutt v. Hanson, 147 A.3d 352

Parties married ~17 years with two minor children; divorce granted for irreconcilable differences after contested property/spousal-support hearing.
The parties owned interests in six parcels (marital home, adjacent 48–50 acre "carriage house lot" gifted to Hutt, three LLC-owned properties, and an undeveloped Northport parcel gifted to Hutt alone).
Hutt received $250,000 in life-insurance proceeds during the marriage and used those nonmarital funds to pay off a marital loan related to Bucksport property.
Trial court found Hutt’s nonmarital interest in the carriage house lot to be $75,000 and credited her $250,000 contribution toward marital indebtedness.
Court set aside the undeveloped Northport parcel to Hutt as nonmarital and ordered sale of the other five properties, directing that Hutt receive the first $325,000 of net sale proceeds (to account for $75,000 nonmarital interest + $250,000 contribution), with remaining proceeds divided equally.
Court denied spousal support (now or in the future), allocated tax exemptions for children, and awarded no attorney fees; Hanson appealed.

Issue	Plaintiff's Argument (Hanson)	Defendant's Argument (Hutt)	Held
Whether trial court had to expressly address each §953(1) factor	Court erred by not specifically addressing every statutory factor	Court considered factors sufficiently; explicit enumeration not required	Trial court not required to enumerate each factor; findings need only permit review and show consideration of relevant factors
Whether court clearly erred in factual findings (value of nonmarital land and $250,000 contribution)	Court’s valuations were incorrect and unsupported	Trial court credited Hutt’s persuasive testimony and evidence of payments	Findings were supported; no clear error—trial court credibility determinations deferred to on appeal
Whether allocation method (first $325,000 from sale of any of five parcels) was an abuse of discretion	Court should have tied reimbursement to sale of a specific property or used a different division	Allocation for first $325,000 across sales reasonably recognized nonmarital interest and contribution	Allocation was within bounds of reasonableness and not an abuse of discretion
Whether misstatement about paying off "mortgage" was reversible error	Mislabeling the debt as a mortgage undermines the award	The misstatement was harmless and did not affect substantial rights	Error was harmless under M.R. Civ. P. 61; judgment affirmed

Ehret v. Ehret, 135 A.3d 101 (Me. 2016) (appellate-review standard for trial findings)
Doucette v. Washburn, 766 A.2d 578 (Me. 2001) (equitable property division need not be equal)
Shanoski v. Miller, 780 A.2d 275 (Me. 2001) (trial court need not enumerate every statutory factor; findings must allow review)
Violette v. Violette, 120 A.3d 667 (Me. 2015) (requirement to set aside nonmarital property and deference to trial credibility)
Charette v. Charette, 60 A.3d 1264 (Me. 2013) (abuse-of-discretion framework for property division)
Starrett v. Starrett, 101 A.3d 435 (Me. 2014) (review of valuations and findings)
Burrow v. Burrow, 100 A.3d 1104 (Me. 2014) (standards for factual findings in family law matters)
Peters v. Peters, 697 A.2d 1254 (Me. 1997) (court may accept a party’s testimony about value)
Viola v. Viola, 109 A.3d 634 (Me. 2015) (standard for reviewing marital property distribution)
Gordon v. Cheskin, 82 A.3d 1221 (Me. 2013) (harmless-error principle for misstatements of fact)