James A. Ehret v. Deborah B. Ehret
135 A.3d 101
| Me. | 2016Background
- James and Deborah Ehret married in 1988; they have two adult children and one minor son with behavioral/mental-health needs.
- James is an airline pilot with greater earning capacity; Deborah has limited recent employment due to physical and mental health issues.
- After a three-day hearing, the District Court entered a divorce judgment awarding Deborah the marital residence, some bank accounts, and spousal support; James received certain vehicles and other assets and was assigned significant debts and college tuition obligations for an adult child.
- The court’s attached child support worksheet listed James’s annual gross income as $95,000 (James’s financial statement showed $87,012), but the judgment contained no explanatory findings about how that figure was reached.
- James timely moved under M.R. Civ. P. 52 for specific findings regarding his income and other issues; the court denied the motion and James appealed.
- The Supreme Judicial Court vacated the child support order, spousal support order, property distribution, and the denial of the Rule 52 motion as to income, and remanded for specific findings and reconsideration consistent with statutory factors.
Issues
| Issue | Plaintiff's Argument (James) | Defendant's Argument (Deborah) | Held |
|---|---|---|---|
| Trial court’s gross income finding for James | Court erred/abused discretion in finding annual gross income $95,000; if income was imputed court failed to find voluntary underemployment | Implicitly supported the court’s worksheet figure / court discretion to determine income | Vacated income/gross calculation; remanded because judgment lacked findings explaining basis for the $95,000 figure |
| Effect of James’s timely Rule 52 motion on appellate review | Denial of motion prevents inferring findings; requires remand for specific findings | Court denied motion but judgment contained no findings to permit review | Court held that because Rule 52 motion was timely, appellate court cannot infer findings; remand required for findings on income |
| Spousal support award ($550/week) adequacy and relation to ability to pay | Award exceeds ability to pay and lacks adequate findings or statutory-factor analysis | Court weighed factors and exercised discretion to provide support for Deborah’s reasonable standard of living | Vacated spousal support; remand for findings that address all 19-A M.R.S. § 951-A(5) factors, income, earning capacity, and interplay with property division and child support |
| Property distribution and allocation of debts (including adult child tuition) | Distribution allocated disproportionate debt to James; court exceeded authority assigning adult child tuition; lacked valuation and table showing overall distribution | Court made equitable distribution in its discretion | Vacated distribution; remand for classification of assets, monetary valuations, table-form distribution, and explanation of rationale (reconsider in light of income findings) |
Key Cases Cited
- Bayley v. Bayley, 602 A.2d 1152 (Me. 1992) (absence of a request for findings permits assuming necessary findings; different rule when findings were timely requested)
- Koszegi v. Erickson, 855 A.2d 1168 (Me. 2004) (court may impute income when a party is voluntarily underemployed)
- Wrenn v. Lewis, 818 A.2d 1005 (Me. 2003) (discussing imputing income and statutory grounds)
- Payne v. Payne, 899 A.2d 793 (Me. 2006) (income determinations are factual findings reviewed for clear error; imputation requires findings on amount and basis)
- Williams v. St. Pierre, 889 A.2d 1011 (Me. 2006) (findings must be supported by competent record evidence)
- Ramsdell v. Worden, 17 A.3d 1224 (Me. 2011) (requirement to classify property as marital or nonmarital)
- Laqualia v. Laqualia, 30 A.3d 838 (Me. 2011) (courts should assign monetary values when credible information is offered)
- Bond v. Bond, 17 A.3d 1219 (Me. 2011) (encourages table-form property distributions to show overall allocation)