Omayaka v. Omayaka, 12 A.3d 96

Marital dissolution culminated in a 2007 circuit court divorce judgment after a July 5, 2007 hearing.
Appellant (husband) challenged the dissipation of marital assets during the pendency of the divorce.
Appellee (wife) testified to spending funded from withdrawals but denied dissipation.
Circuit Court denied dissipation and awarded no monetary award; divorce granted to wife.
Appellant sought reversal or remand for a judgment in his favor; the Court of Appeals granted certiorari and affirmed.
Key issue is whether withdrawals constituted dissipation of assets to reduce property for equitable distribution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court correctly found no dissipation of marital assets.	Omayaka (Appellant) contends prima facie dissipation was shown.	Omayaka (Appellee) argues expenditures were for family purposes and not dissipation.	No reversible error; dissipation burden not met; expenditures explained.
What is the proper burdens of production and persuasion in dissipation claims?	Appellant asserts improper burden shifting and failure to apply Jeffcoat.	Appellee asserts proper burden allocation and proof of expenditures.	Court-applied framework consistent with Maryland law; burden remained on movant to prove dissipation.
Did the trial court adequately evaluate the credibility and evidentiary support for expenditures?	Appellant argues lack of corroborating documentation and improper weighing of testimony.	Appellee’s testimony was found credible and adequately explained expenditures.	Yes; appellate court upheld credibility findings and sufficiency of explanation.
Should the case be vacated and remanded to enter judgment for Appellant based on prima facie evidence?	Appellant seeks remand with instructions to enter judgment for him.	Appellee disputes remand and maintains no dissipation established.	No remand; no clear error; judgment affirmed.

Sharp v. Sharp, 58 Md.App. 386, 473 A.2d 499 (Md. Ct. App. 1984) (dissipation doctrine and burden framework)
Choate v. Choate, 97 Md.App. 347, 629 A.2d 1304 (Md. Ct. App. 1993) (burdens of production and persuasion in dissipation)
Jeffcoat v. Jeffcoat, 102 Md.App. 301, 649 A.2d 1137 (Md. Ct. App. 1994) (prima facie case and shifting burdens in dissipation)
Beck v. Beck, 112 Md.App. 197, 684 A.2d 878 (Md. Ct. App. 1996) (affirming standard for reviewing dissipation findings)
Solomon v. Solomon, 383 Md. 176, 857 A.2d 1109 (Md. 2004) (historical context and standard of review for dissipation)
Welsh v. Welsh, 135 Md.App. 29, 761 A.2d 949 (Md. Ct. App. 2000) (relevant factors: timing and purpose of expenditures)
Heger v. Heger, 184 Md.App. 83, 964 A.2d 258 (Md. Ct. App. 2009) (critical time frame for assessing dissipation during separation and divorce)
Figgins v. Cochrane, 174 Md.App. 1, 920 A.2d 572 (Md. Ct. App. 2007) (illustrates non-pecuniary considerations in dissipation rulings)