Petrzelka v. Goodwin, 461 P.3d 1134

Peggy Petrzelka (b. ~1962) and James Goodwin (b. ~1943) married in September 2004, separated February 2015, and divorced after a two-day bench trial in February 2018.
During the marriage the parties largely maintained separate finances and only shared a few limited joint living expenses; Petrzelka continued a full-time teaching career and had purchased the marital home pre-marriage.
Goodwin retired in 2012, later moved to California after separation, and had a history of overspending and carrying credit-card debt; after separation he drew from his retirement accounts while Petrzelka stopped contributing to hers.
The trial court found Goodwin’s claimed monthly expenses largely reasonable but excessive in some items and determined his income at $3,571/month by combining Social Security/retirement with imputed part-time earnings ($15/hr × 20 hrs/week).
The court denied Goodwin alimony, concluding he was capable of meeting his own needs, and set the marital valuation period for retirement assets from the marriage date (Sept. 4, 2004) to March 1, 2015 (near separation), rather than valuing at trial/divorce date.
Goodwin appealed the alimony denial (challenging income imputation and related findings) and the retirement-account valuation date; the Court of Appeals affirmed and denied appellate fees to both parties.

Issue	Goodwin's Argument	Petrzelka's Argument	Held
Whether the court erred by denying alimony	Court abused discretion by imputing income to Goodwin despite his retirement and thus wrongly concluded he could meet needs	Trial court properly considered statutory alimony factors, imputed reasonable part‑time income based on skills and activities, and denial was equitable	Affirmed: court did not abuse discretion; imputation and denial supported by findings
Whether imputing $15/hr income was unsupported	$15/hr was assertedly based on an unsupported factual premise (CA minimum wage) and lacked evidentiary support	Court’s written findings tie $15/hr to Goodwin’s marketable skills and ability to obtain such work, not to minimum‑wage assertion	Affirmed: written findings control; record supports imputation at $15/hr
Whether court should have valued retirement accounts at trial/divorce date	Valuation should be at time of decree/trial; using March 1, 2015 undervalues marital estate	Court reasonably deviated because Petrzelka stopped contributing and Goodwin began dissipating accounts after separation	Affirmed: court permissibly deviated from general rule based on circumstances
Whether appellate attorney fees should be awarded	Goodwin seeks fees because he got fees below; Petrzelka seeks fees as prevailing party	Petrzelka argues appeal not frivolous; Goodwin not prevailing on appeal	Denied: Goodwin not prevailing; Petrzelka not entitled to fees because none awarded below and appeal not frivolous

Gardner v. Gardner, 452 P.3d 1134 (Utah 2019) (standard of review for family‑law adjustments and imputation principles)
Rayner v. Rayner, 316 P.3d 455 (Utah Ct. App. 2013) (trial court has broad discretion to value marital estate at non‑standard dates)
Jacobsen v. Jacobsen, 257 P.3d 478 (Utah Ct. App. 2011) (general rule: value marital estate at time of divorce/trial, but deviation allowed with findings)
Hartvigsen v. Hartvigsen, 437 P.3d 1257 (Utah Ct. App. 2018) (affirming income imputation despite long hiatus from employment when evidence supports earning capacity)
Leppert v. Leppert, 200 P.3d 223 (Utah Ct. App. 2009) (imputing income to nonworking spouse when capable of earning)
Hansen v. Hansen, 325 P.3d 864 (Utah Ct. App. 2014) (imputation appropriate despite advancing age if capable of work)
Rule v. Rule, 402 P.3d 153 (Utah Ct. App. 2017) (alimony purpose: maintain marital standard of living; consider standard at time of separation)
Stonehocker v. Stonehocker, 176 P.3d 476 (Utah Ct. App. 2008) (prevailing party awarded appellate fees when awarded fees below)