Munoz-Madrid v. Carlos-Moran, 427 P.3d 420

Wife (Patricia Munoz-Madrid) sought divorce and alimony after a long marriage; bench trial held and decree entered in Nov. 2016.
Wife testified to gross monthly income ~$2,005 and net ~$1,600; she listed monthly expenses around $3,200 and testified to a monthly rent obligation of $800 (paid partially), leaving a monthly deficit.
Husband (Martin Carlos-Moran) declared gross monthly income ~$4,281 and net between ~$3,393–$3,831; monthly expenses roughly $3,300–$3,500.
Wife did not provide documentary support for her financial declaration; a friend testified corroborating rent and utility burdens while Wife housed children.
The district court found Wife had a monthly deficit and awarded alimony of $548/month for 12 years, effective May 1, 2016.
Husband appealed only the finding of Wife’s financial need and the resulting alimony award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wife demonstrated financial need to support alimony	Wife relied on her financial declaration and corroborating testimony showing expenses exceeded income	Husband argued Wife failed to provide supporting documentation, so court could not find need under Utah Code §30-3-5	Court upheld award: testimonial evidence and corroboration allowed imputation of reasonable expenses despite lack of documents

Vanderzon v. Vanderzon, 402 P.3d 219 (Utah Ct. App. 2017) (alimony determinations reviewed for abuse of discretion)
Rule v. Rule, 402 P.3d 153 (Utah Ct. App. 2017) (primary purposes of alimony explained)