In re the Marriage of: Christopher Hutchenson Owen v. Angela Dawn Owen, A16-396

Christopher and Angela Owen married in 2006, had two minor children, and divorced after Christopher petitioned in 2014. Trial on property division and spousal maintenance occurred July 2015; a CSM earlier issued findings on child support and incomes.
The CSM found Christopher’s gross monthly income was $1,909 and imputed gross monthly potential income of $1,732 to Angela; the CSM also made findings about each party’s monthly living expenses.
Disputed marital items included Angela’s student loan debt (~$32,354.62), Christopher’s alleged smaller student loans, and a 2013 joint tax refund (~$6,800 gross, ~$4,500 net) Christopher used to help start a business.
The district court awarded each spouse half of Angela’s student loan debt ($16,176.31 by clerical error), ordered Christopher to reimburse Angela $1,000 from the 2013 refund, and ordered refiling of 2014 tax returns to allocate dependents separately.
The district court adopted the CSM’s gross income figures but found Angela’s reasonable monthly expenses were $1,791 (different from the CSM’s $1,200) and awarded Angela temporary spousal maintenance of $300/month for 18 months. The court made no explicit findings about Christopher’s monthly expenses or either party’s net (take-home) income.
Christopher moved to amend or for new trial; the district court denied relief. On appeal the court affirmed the property division but reversed and remanded the spousal maintenance award for insufficient findings.

Issue	Christopher's Argument	Angela's Argument	Held
Division of marital debt and assets	District court erred and abused discretion in allocating student loans, tax refund, and ordering tax refiling	Division was just and accounted for incomes, needs, contributions, and business startup	Affirmed — no clear abuse of discretion in property/debt division
Award of temporary spousal maintenance	Court abused discretion by awarding maintenance without findings on obligor’s expenses and parties’ net incomes	Court considered CSM incomes and Angela’s needs and found Christopher could pay modest temporary maintenance	Reversed and remanded — insufficient findings on Christopher’s monthly expenses and parties’ net incomes
Use of CSM findings/stipulation	CSM findings on expenses should control; court failed to use them for expenses	Stipulation covered incomes only; district court may re-evaluate expenses	Held district court treated stipulation as applying only to incomes; cannot impute CSM expense findings to the district court
Need to recalculate child support after maintenance award	Court should have recalculated child support after awarding spousal maintenance	Not addressed because court declined to recalc; maintenance may be temporary	Not reached — remand on maintenance makes recalculation issue unnecessary to decide now

Sirek v. Sirek, 693 N.W.2d 896 (Minn. App. 2005) (appellate review of district court property division limited to abuse-of-discretion standard)
Stich v. Stich, 435 N.W.2d 52 (Minn. 1989) (district court must make sufficiently detailed findings to permit appellate review of maintenance awards)
Cummings v. Cummings, 376 N.W.2d 726 (Minn. App. 1985) (without findings as to parties’ expenses, appellate review of maintenance is impossible)
Kostelnik v. Kostelnik, 367 N.W.2d 665 (Minn. App. 1985) (district court must determine payor spouse’s net or take-home pay when assessing ability to pay maintenance)
Erlandson v. Erlandson, 318 N.W.2d 36 (Minn. 1982) (maintenance analysis balances recipient’s need against obligor’s financial condition)