Ralph Monty Layne, Jr. v. Sudie Mae Layne
77 N.E.3d 1254
Ind. Ct. App.2017Background
- In 1998, the parties signed a premarital agreement excluding the Roosevelt Road Property from Wife's interest, and they later married in 2005.
- Husband’s sole income since around 2008 has been about $1,700 per month from disability, while Wife ran a business that ultimately failed and led to bankruptcy.
- Starting in 2008, the couple's debts and expenses rose, and they commingled some assets and funded Wife’s business with marital assets.
- Prior to the Petition Date (dissolution filing on January 24, 2014), Husband received approximately $202,000 from his parents’ funds for transfers to his daughter and a home for his son, affecting asset tracing.
- Husband later inherited his parents’ home on Prairie Avenue, with transfers to his son occurring after the Petition Date, making those transfers and the Prairie Avenue property subject to marital estate considerations.
- The trial court valued several assets including Roosevelt Road Property (with the Premarital Agreement), Lake Property, and various personal property, and ordered a Dissipation Equalization Payment of $91,000 in favor of Wife.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the marital estate division was an abuse of discretion | Layne argues the court improperly clawed back $182,000 dissipated assets and over-allocated to Wife. | Layne contends dissipation near petition date justifies adjustment and the award exceeds the net estate. | Division upheld; dissipation properly considered with a $91,000 payment to Wife. |
| Whether the premarital agreement is enforceable | Husband contends the agreement is invalid or not executed in contemplation of marriage. | Wife argues it is a valid premarital agreement excluding Roosevelt Road Property. | Premarital agreement is valid and enforceable. |
| Whether the Roosevelt Road Property and the ATV were properly excluded from the marital estate | Wife argues property should be included due to commingling or other reasons; ATV was mischaracterized. | Husband concedes ATV was bought pre-separation; exclusion based on premarital agreement and subsequent sale; the court did not err. | Exclusion of Roosevelt Road Property affirmed; ATV exclusion deemed harmless error. |
Key Cases Cited
- Boetsma v. Boetsma, 768 N.E.2d 1016 (Ind. Ct. App. 2002) (premarital agreement construction and liberally enforcing intent)
- Brackin v. Brackin, 894 N.E.2d 206 (Ind. Ct. App. 2008) (premarital agreements construed in light of intent and context)
- Trabucco v. Trabucco, 944 N.E.2d 544 (Ind. Ct. App. 2011) (two-tier standard of review for findings on dissolution)
- Balicki v. Balicki, 837 N.E.2d 532 (Ind. Ct. App. 2005) (deference to factual findings; dissipation evidence relevance)
- Pitman v. Pitman, 721 N.E.2d 260 (Ind. Ct. App. 1999) (pre-separation dissipation; limits on monetary adjustments from dissipation)