In Re the Marriage of Melissa Lyne Snider and Jonathan Edward Snider Upon the Petition of Melissa Lyne Snider, and Concerning Jonathan Edward Snider
15-1985
| Iowa Ct. App. | Apr 19, 2017Background
- Melissa and Jonathan Snider married in 2000; Melissa stayed home to raise children, while Jonathan operated a horse-shoing business with an average income around $52,000.
- After separation, Melissa worked part-time; the parties disputed whether she should work and the trial court valued marital assets for dissolution.
- A day-before-trial stipulation listed asset valuations, including a 2010 GMC Acadia, two Pilot Grove bank accounts, and tools of trade valued at $20,000, but this value was disputed.
- The district court used the second stipulation (not admitted as exhibit) and adopted its values, awarding Melissa an equalization payment of $9,000.
- Jonathan appealed, challenging the valuations of the tools of trade, the GMC Acadia, and the Pilot Grove accounts; the court modified, removing the disputed tool valuation.
- Upon review, the Iowa Court of Appeals affirmed the decree as modified, recalculating assets and liabilities and ordering a smaller equalization payment of $15,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were tools of trade valued properly? | Jonathan argues the tools were valued without sufficient record support. | Snider argues the court should adopt the stipulation value. | Tools value rejected; removed from equity calculation; equalization adjusted. |
| Was the GMC Acadia valuation correct? | Jonathan contends the vehicle was valued incorrectly. | Melissa asserts the second stipulation value should control. | Valuation based on second stipulation; no error found. |
| Are the Pilot Grove bank-account valuations supported? | Jonathan challenges the $4,420 and $1,015.62 balances. | Melissa relies on the second stipulation and Jonathan's financial affidavit. | Valuations within the evidentiary range; not disturbed. |
| Is the final equalization payment equitable? | Jonathan should not benefit from removing tool value; equity should reflect actual asset values. | Melissa argues considering factors, a smaller equalization is fair. | Equalization reduced to $15,000 to reflect factors; not an automatic equal split. |
Key Cases Cited
- In re Marriage of Briddle, 756 N.W.2d 35 (Iowa 2008) (stips are contracts; court may reject unfair property stipulations)
- In re Marriage of Ask, 551 N.W.2d 643 (Iowa 1996) (stipulations may be limited or modified to reflect fairness)
- In re Marriage of Dennis, 467 N.W.2d 806 (Iowa Ct. App. 1996) (deference to district-court valuations when supported by record)
- In re Marriage of Vieth, 591 N.W.2d 639 (Iowa Ct. App. 1999) (deference to credibility findings or corroborating evidence)
- In re Marriage of Higgins, 507 N.W.2d 725 (Iowa Ct. App. 1993) (accepting valuation based on financial affidavit)
- In re Marriage of Hoak, 364 N.W.2d 185 (Iowa 1985) (valuation within evidence range; standard of review)
- In re Marriage of McDermott, 827 N.W.2d 671 (Iowa 2013) (de novo review with weight to district court findings)
- In re Marriage of Okland, 699 N.W.2d 260 (Iowa 2005) (appellate discretion on attorney-fee awards; equity considerations)
- In re Marriage of Anliker, 694 N.W.2d 535 (Iowa 2005) (equitable division factors; not always equal)