Michael v. Finucan v. Laurel (Finucan) Williams, 2013 ME 75

Michael (airline pilot, ~$108,000/yr) and Laurel (marketing director, ~$50,000/yr) separated after a 1995 marriage and have two children. Both filed for bankruptcy post-separation.
Laurel had been covered on Michael’s employer health plan; her employer makes a $3,500/year payment that she directs to either an IRA or health insurance (she directs it to an IRA).
Tax underwithholding by Michael while owning a SC home produced unpaid federal tax liabilities for 2009–2011 (Michael owed ~$28,000); Laurel paid her past-due taxes but anticipated a 2012 liability.
District Court awarded child support, $1,000/month general spousal support for 7 years 10 months, ordered Michael to maintain health insurance for Laurel ("throughout COBRA and thereafter") and to be solely responsible for any and all IRS debts for previous, current, or future tax years.
Michael moved to amend; court issued an amended judgment preserving the spousal support amount, clarifying the health-insurance duty, and reiterating Michael’s responsibility for IRS debts; Michael appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court properly ordered Michael to maintain health insurance (COBRA and thereafter) as spousal support	Michael: order rests on speculation, lacks competent evidence of cost/availability, court failed to make §951‑A findings, and order is indefinite	Laurel: (implicitly) award appropriate to cover her loss of employer-based coverage; evidence that COBRA cheaper than private coverage	Court vacated the entire spousal support award (monthly payments + insurance) and remanded for redetermination consistent with 19‑A M.R.S. §951‑A because record lacked competent evidence on costs and the insurance component was effectively indefinite, possibly exceeding statutory presumptive durational limits
Whether court properly ordered Michael to pay Laurel’s "future" federal tax debts	Michael: judgment improperly makes him responsible for Laurel’s future nonmarital tax debt, exceeding court's authority	Laurel: (implicitly) intended to allocate outstanding joint/marital tax liabilities to Michael	Court vacated and remanded the tax-allocation language for clarification; noted the order could be interpreted within authority if limited to unpaid marital tax years (2009–2011), but cannot impose indefinite responsibility for future nonmarital debts

Laqualia v. Laqualia, 30 A.3d 838 (Me. 2011) (health insurance as form of spousal support and limits on debt allocation authority)
Efstathiou v. The Aspinquid, Inc., 956 A.2d 110 (Me. 2008) (standard of review for spousal support and statutory interpretation of §951‑A)
Potter v. Potter, 926 A.2d 1193 (Me. 2007) (need for sufficient findings to permit appellate review)
Payne v. Payne, 899 A.2d 793 (Me. 2006) (presumption limiting duration of general spousal support to half the marriage)
Hannum v. Bd. of Envtl. Prot., 832 A.2d 765 (Me. 2003) (fact-finder must rely on evidence, not speculation)
Hess v. Hess, 927 A.2d 391 (Me. 2007) (marital debt treated as property for allocation under §953)