Molly G. (Lachance) Jandreau v. Daniel L. Lachance, 116 A.3d 1273

Molly Jandreau (wife) and Daniel LaChance (husband) divorced after a 1999 marriage; one child born 2000. Wife receives SSDI totaling $14,212/year; husband’s annual income found to be $87,896.
Parties agreed to interim child support and $1,600/month interim spousal support; husband paid June 2013 in full, paid $50 in July, then stopped paying; wife moved for contempt and filed updated financials; husband did not.
At trial, wife testified she is disabled (anxiety, PTSD), on multiple medications, has limited recent work history, and will lose husband’s employer health insurance after divorce, facing higher Medicare and possible out‑of‑pocket mental‑health costs; her expenses exceed income by about $1,000/month.
The court’s divorce judgment: $230/week child support; equalizing property payment to wife of $18,837 leaving roughly equal net worths; allocation of dependency exemption to wife (with option for husband to buy it); judgment stated "no spousal support shall be paid now or in the future" and each party responsible for own attorney fees.
The court found husband in contempt for failing to pay interim spousal support and entered a writ for unpaid interim spousal support (~$20,750), but declined to adjust the interim support amount as a contempt sanction.
Wife appealed, arguing the trial court abused its discretion by denying spousal support and denying attorney fees; the Supreme Judicial Court vacated those portions and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of permanent spousal support was an abuse of discretion	Jandreau: given disability, minimal income, medical costs, and disparity in earning power, some spousal support is required; property division and child support do not eliminate her need	LaChance: (did not file brief on appeal) court relied on child support, tax exemption allocation, incomes, and property division to deny spousal support	Vacated and remanded: trial court abused discretion; its cited factors and record do not support complete denial—remand for reconsideration under §951‑A factors
Whether denial of attorney fees was an abuse of discretion	Jandreau: seeks fees because she cannot afford them, husband failed to file required financial affidavit, and contempt for nonpayment increased her costs	LaChance: (no appellate argument)	Vacated and remanded: abuse of discretion to deny fees given income disparity, contempt finding, and failure to file affidavit without good cause

Potter v. Potter, 926 A.2d 1193 (Me. 2007) (trial court discretion on spousal‑support awards; appellate review for abuse of discretion)
Payne v. Payne, 899 A.2d 793 (Me. 2006) (standards on spousal support discretion)
Bonnevie v. Bonnevie, 611 A.2d 94 (Me. 1992) (equal property division does not preclude spousal support where earning disparity forces consumption of assets)
Sewall v. Snook, 687 A.2d 234 (Me. 1996) (vacating denial of spousal support where wife's expenses exceed income despite property award)