Lundy v. Lundy, 445 S.W.3d 518

Mack and Sandy Lundy married October 30, 2012, separated June 2013; Sandy sued for absolute divorce alleging general indignities on June 27, 2013.
Sandy alleged Mack was overbearing, wanted her committed, belittled her (called her "stupid"), disparaged her counseling, threatened to burn her DVDs, and quoted Bible verses to criticize her faith.
Sandy testified to repeated belittling and a parking-lot confrontation after a counseling session; her sister Debbie Davis testified Sandy appeared sad, nervous, and scared but admitted she witnessed no disputes and related only what Sandy told her.
The Faulkner County Circuit Court granted the divorce; Mack appealed, arguing insufficient corroboration and evidence of general indignities.
The Court of Appeals reviewed the record de novo but will not disturb findings unless clearly erroneous and focused on whether there was the required corroboration for general indignities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sandy proved the statutory ground of general indignities	Sandy: Mack's repeated belittling, threats, attempted control, and specific incidents rendered her life intolerable	Mack: Allegations are uncorroborated, conclusory, and amount to mere uncongeniality/quarrelsomeness	Reversed — Sandy failed to produce the slight corroboration required; evidence was insufficient
Whether testimony from a relative repeating plaintiff's statements constitutes corroboration	Sandy: Sister's testimony about Sandy's demeanor and recounting of incidents supports Sandy's claims	Mack: Sister's testimony is hearsay about what she was told, not independent corroboration	Held: Sister's testimony was based on what Sandy told her and did not provide required corroboration
Whether the evidence showed habitual/settled manifestations (not just occasional quarrels)	Sandy: Series of incidents and ongoing belittling showed settled estrangement and contempt	Mack: Incidents were isolated, not a habitual settled manifestation	Held: Court found evidence did not establish habitual, continuous settled indignities
Whether slight corroboration suffices absent collusion	Sandy: No collusion; thus slight corroboration should be enough	Mack: Even slight corroboration must be independent and was lacking here	Held: Lack of independent corroboration meant the divorce could not be sustained; reversal required

Hunter v. Haunert, 270 S.W.3d 339 (Ark. App.) (standard of review in domestic-relations appeals)
Gunnell v. Gunnell, 780 S.W.2d 597 (Ark. App.) (divorce is statutory; must prove statutory ground)
Poore v. Poore, 61 S.W.3d 912 (Ark. App.) (definition and required proof of general indignities)
Pomraning v. Pomraning, 682 S.W.2d 775 (Ark. App.) (examples of manifestations constituting indignities)
Dee v. Dee, 258 S.W.3d 405 (Ark. App.) (testimony that is merely general or conclusory is insufficient)
Moore v. Davidson, 145 S.W.3d 833 (Ark. App.) (rule requiring corroboration to prevent collusion; slight corroboration may suffice when no collusion)
Coker v. Coker, 423 S.W.3d 599 (Ark.) (illustrative case where slight corroboration was found sufficient)