Langwald v. Langwald, 878 N.W.2d 71

Nathan and Patricia Langwald married in 1994, had three children, and operated family farming and rental businesses; Nathan owned farmland purchased pre-marriage by contract for deed.
Nathan suffered a traumatic brain injury in 2011; Patricia managed the household, rentals, business records, and obtained his power of attorney; she rented farm ground in 2012 and Nathan resumed some farming in 2013.
Patricia initially filed for divorce in Montana, dismissed that action, and Nathan later sued in North Dakota.
At trial each party presented competing real-estate valuation experts; the district court credited Nathan’s expert, valued the marital estate at $2,008,348.98, and awarded Nathan about 61% and Patricia about 39% of the assets (with a $100,000 equalization/payment ordered).
The court gave Patricia primary residential responsibility for the children and ordered Nathan to pay child support based on annual income of $28,536 producing a $699/month obligation.

Issue	Plaintiff's Argument (Nathan)	Defendant's Argument (Patricia)	Held
Real property valuation	Court should accept Nathan’s expert valuation	Court erred by discounting Patricia’s expert and experience	Court affirmed: district court’s valuation was within evidentiary range and not clearly erroneous (credited Nathan’s expert)
Property distribution	Award of farming property and debt to Nathan is equitable given family origin and his intent to farm	Distribution was substantially disproportionate and inadequately explained	Court affirmed: district court applied Ruff-Fischer factors and adequately explained disparity (result equitable)
Child support — income calculation	Support based on Nathan’s reported income ($28,536) is appropriate	Court should impute higher income reflecting rental/farming earning capacity and explain calculations	Court reversed and remanded: district court failed to state how net income was determined as required by guidelines
Adequacy of findings for support order	Adopt parties’ proposed calculations without detailed findings	Court must make explicit findings and calculations for net income under guidelines	Court held that insufficient detail on net income is reversible error and remanded for proper calculation

Kostelecky v. Kostelecky, 714 N.W.2d 845 (N.D. 2006) (property valuation reviewed for clear error; valuations within evidence range upheld)
Hoverson v. Hoverson, 828 N.W.2d 510 (N.D. 2013) (property distribution reviewed for clear error under Ruff‑Fischer factors)
Ulsaker v. White, 717 N.W.2d 567 (N.D. 2006) (requirement to value entire marital estate before equitable distribution)
Buchholz v. Buchholz, 590 N.W.2d 215 (N.D. 1999) (child support involves mixed standards; failure to follow guidelines is legal error)
Verhey v. McKenzie, 763 N.W.2d 113 (N.D. 2009) (district court errs as a matter of law if it fails to comply with child support guidelines)
Krueger v. Krueger, 800 N.W.2d 296 (N.D. 2011) (insufficient detail in net‑income findings requires reversal)
Pember v. Shapiro, 794 N.W.2d 435 (N.D. 2011) (child support findings must adequately explain net income calculation)