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In Re the Marriage of Cara Lynn Matteson and Taylor Bryce Matteson Upon the Petition of Cara Lynn Matteson, and Concerning Taylor Bryce Matteson
16-0401
| Iowa Ct. App. | Jan 25, 2017
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Background

  • Taylor and Cara Matteson divorced after an eight-year marriage; they have two children (born 2010, 2012). Parties separated in 2014; Cara moved to Marion, Taylor stayed in Manchester.
  • Temporary order gave joint physical care (Cara 4 days/week; Taylor 3 days/week); temporary child support and spousal support were ordered.
  • At trial (Oct 2015) Taylor earned about $63,174/year; Cara worked part time (~$15,000/year) and was returning to school for teaching credentials.
  • District court awarded joint legal custody, physical care to Cara, child support ($1,104.27/month), spousal support ($1,000/month for 30 months), split retirement accounts equally, allocated premarital accounts to Cara, and ordered Taylor to pay $6,000 of Cara's trial attorney fees.
  • On appeal the court affirmed custody, child support, spousal support, dependency exemption split, and trial attorney-fee award; it modified visitation (increased summer time to four weeks) and adjusted property division to give Taylor his Edward Jones IRA.

Issues

Issue Plaintiff's Argument (Taylor) Defendant's Argument (Cara) Held
Physical care Court should continue joint physical care from temporary order or award physical care to Taylor Cara better suited as primary physical caregiver; Taylor undermined her relationship with children Physical care awarded to Cara (joint legal custody retained); joint physical care inappropriate due to conflict, communication issues, and past caregiving
School decision authority As joint legal custodian Taylor contends he has equal participation and should influence school choice Cara, as physical-care parent, should have final say when parents disagree Cara has final decision on where children attend school
Visitation schedule Seeks more midweek overnight visits and additional summer time District schedule adequate but limited by best interests Affirmed alternating weekends + midweek evening (when not weekend), alternating holidays; modified to grant Taylor four weeks summer visitation (two 2-week blocks)
Child support & income imputation Argues court miscalculated; sought higher imputation to Cara and lower annualized income for himself Court used Cara's current realistic income (~$15,000) and Taylor's annual income (~$63,174) Child support calculation affirmed; court's income findings supported by record
Property division Challenges designation of $76,779.20 as Cara's premarital assets and claims Edward Jones IRA was his premarital asset District court treated some accounts as premarital to Cara and divided retirement equally Modified property division to award Edward Jones IRA to Taylor; otherwise affirmed equitable distribution
Spousal support Argues no spousal support necessary because Cara can support herself (higher earning capacity) Support needed to complete education and obtain stable employment Spousal support of $1,000/month for 30 months affirmed (concurring judge would shorten/step-down)
Attorney fees (trial & appeal) Challenges trial fee award and seeks reversal of fee obligation; requests appellate fees Cara sought contribution to trial fees and appellate fees District court's $6,000 trial fee award to Cara affirmed; no appellate fees awarded to either party

Key Cases Cited

  • In re Marriage of Fennelly, 737 N.W.2d 97 (Iowa 2007) (standard for de novo review and factors for property division)
  • In re Marriage of Hansen, 733 N.W.2d 683 (Iowa 2007) (parental support of other's relationship and joint physical-care factors)
  • In re Marriage of Hoffman, 867 N.W.2d 26 (Iowa 2015) (physical-care parent’s authority on home/school decisions)
  • In re Marriage of Okland, 699 N.W.2d 260 (Iowa 2005) (allocation of tax dependency exemptions and equitable considerations)
  • In re Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006) (marital estate includes premarital property and how premarital status factors into division)
Read the full case

Case Details

Case Name: In Re the Marriage of Cara Lynn Matteson and Taylor Bryce Matteson Upon the Petition of Cara Lynn Matteson, and Concerning Taylor Bryce Matteson
Court Name: Court of Appeals of Iowa
Date Published: Jan 25, 2017
Docket Number: 16-0401
Court Abbreviation: Iowa Ct. App.