Marroquin v. Marroquin, 440 P.3d 757

Heather and Renson Marroquin married in 2005; Renson owns 99% of Deluxe Vending LLC, operating vending machines and micro-markets; Heather had only limited involvement.
Heather filed for divorce in 2014; valuation of Deluxe Vending was the central dispute at trial.
Heather’s expert (no valuation credentials) offered widely varying income-based valuations (initially $725k–$900k, later up to ~$1.23–$1.53M, then $700k at trial).
Renson’s expert (experienced business valuation CPA) used a net-asset approach and concluded the business value was $152,937, applying a marketability discount and attributing only personal (not institutional) goodwill to Renson.
The district court found Renson’s expert more credible, awarded Deluxe Vending to Renson, ordered him to pay Heather half ($76,468.50), and denied Heather’s post-judgment motion to amend findings or for a new trial.
On appeal, Heather challenged (1) exclusion of institutional goodwill and failure to adjust valuation for reduced liabilities, (2) absence of a payment due date or interest on her award, and (3) denial of a new trial based on alleged trial irregularities (dissipation questioning). The Court of Appeals affirmed.

Issue	Heather's Argument	Renson's Argument	Held
Whether district court erred by not including institutional goodwill in business valuation	Deluxe Vending has institutional goodwill that should be divisible marital property	Goodwill is personal to Renson (sole-operator relationships); not divisible	Court affirmed: goodwill is personal to Renson; exclusion was not an abuse of discretion
Whether court should have adjusted valuation for liabilities reduced after expert reports	Trial testimony showed liabilities were reduced before divorce; valuation should reflect that	Valuations were expert snapshots prepared pre-trial; Heather did not timely request adjustment at trial	Court affirmed: no clear abuse; Heather failed to timely present/change valuation at trial
Whether court abused discretion by not setting payment due date or interest on Heather’s award	Lack of due date/interest leaves Heather unable to access award and is inequitable	Heather can enforce the judgment as any creditor; no evidence she sought enforcement	Court affirmed: no abuse; Heather has remedies to enforce judgment
Whether denial of new trial was error due to trial irregularity (cutting off dissipation questioning)	Court curtailed questioning about alleged dissipation, preventing fair trial	Questions did not tie spending to diminution of marital assets; Heather failed to identify dissipated assets at trial	Court affirmed: no abuse; Heather had opportunity to present evidence and outcome wouldn’t have differed

Sorensen v. Sorensen, 839 P.2d 774 (Utah 1992) (personal goodwill of a sole practitioner is not a divisible marital asset)
Stonehocker v. Stonehocker, 176 P.3d 476 (Utah Ct. App. 2008) (used-business goodwill found to be personal to husband; business akin to sole proprietorship)
Taft v. Taft, 379 P.3d 890 (Utah Ct. App. 2016) (payment terms that give one spouse near-complete discretion over when the other receives her award can be inequitable)
Ebbert v. Ebbert, 744 P.2d 1019 (Utah Ct. App. 1987) (trial court has discretion in valuing marital property; appellate review for abuse of discretion)
Rayner v. Rayner, 316 P.3d 455 (Utah Ct. App. 2013) (factors relevant to dissipation claims and when valuation date may be adjusted)
Parker v. Parker, 996 P.2d 565 (Utah Ct. App. 2000) (trial court may value assets as of a different date when dissipation or concealment occurred)
Maughan v. Maughan, 770 P.2d 156 (Utah Ct. App. 1989) (sanctioning frivolous appeals is reserved for egregious cases)