In re the Marriage of Eastman, 20-1677

Parties married in 1988, no children; lived in multiple states and returned to Iowa in 2015; separation began ~2018 and Larry petitioned for dissolution in 2019.
Larry (72 at trial) worked long-term for Kimball with substantial income (salary + Social Security + pensions); assigned most marital debt in decree.
Rita (65 at trial) had limited recent employment, significant health issues (multiple cancer diagnoses), was largely uninsured pre-dissolution and relied on Larry’s insurance; her only pre-dissolution income was temporary spousal support and later Social Security.
Marital home bought in 2015 for $150,000, encumbered by ~$107,000 mortgage, in serious disrepair (derecho damage); trial court valued it at $150,000 and awarded it to Larry with a $21,500 equity payment to Rita.
The parties kept many rescue dogs; evidence showed at least one dog in Rita’s care suffered fatal neglect and Rita was charged criminally; trial court awarded all dogs to Larry.
Trial court awarded Rita $1,000/month spousal support (reduced to $200/month upon Larry’s retirement), denied Rita’s request for trial attorney fees, and the court’s property and support rulings were largely affirmed on appeal with one modification regarding the retirement reduction.

Issue	Plaintiff's Argument (Rita)	Defendant's Argument (Larry)	Held
Adequacy and duration of spousal support; retirement reduction	Support award inadequate given 30+ year marriage, Rita's unemployment, health, lack of retirement savings; reduction on Larry’s retirement improper	Award appropriate under statutory factors; reduction tied to Larry’s retirement acceptable	Affirmed $1,000/month award, but modified to remove automatic reduction at Larry’s retirement; Larry may seek modification when retirement is imminent or occurs
Valuation and disposition of marital home; sale vs. award to Larry	Home worth more than $150,000; equitable remedy would be sale	Home in disrepair and $150,000 valuation is supported by evidence; awarding to Larry with equalization payment equitable	Court’s $150,000 valuation and award to Larry (with $21,500 payment to Rita) affirmed
Division of dogs (personal property)	Rita was primary caregiver and should keep the dogs; one death was an outlier	Rita’s neglect and evasive conduct show she can’t care for them; awarding to Larry protects animals	Award of all dogs to Larry affirmed due to neglect concerns and financial burden on Rita
Trial and appellate attorney fees	Rita sought trial fees and $6,500 appellate fees due to income disparity and her need	Larry has greater income but assumed most marital debt; trial court’s denial appropriate	Denial of trial fees affirmed; appellate fee request denied (Rita only minimally prevailed)

In re Marriage of Gust, 858 N.W.2d 402 (Iowa 2015) (retirement-related modification of spousal support is generally speculative and should be addressed in modification proceedings)
In re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005) (trial court has broad discretion in spousal-support determinations)
In re Marriage of Mann, 943 N.W.2d 15 (Iowa 2020) (tax consequences of spousal support post-2019 tax law changes)
In re Marriage of Keener, 728 N.W.2d 188 (Iowa 2007) (property-division valuation review: trial court findings within range of evidence will not be disturbed)
In re Marriage of Larsen, 912 N.W.2d 444 (Iowa 2018) (standard of appellate review in dissolution cases)
In re Marriage of Fennelly, 737 N.W.2d 97 (Iowa 2007) (appellate weight given to trial court credibility findings)
In re Marriage of Brown, 776 N.W.2d 644 (Iowa 2009) (dissolution decisions are fact-specific; precedent has limited value)
In re Marriage of Stewart, 356 N.W.2d 611 (Iowa Ct. App. 1984) (courts may avoid placing pets where they will be abused or uncared for)