Rhoades, B. v. Rhoades, R.
144 WDA 2016
| Pa. Super. Ct. | Oct 18, 2016Background
- Beatriz Rhoades (Wife) and Rodney Rhoades (Husband) were married in 2001, separated in 2004; Wife filed for divorce and equitable distribution in 2004; final divorce was entered in 2009 after bifurcation.
- Marriage lasted ~3 years; contested equitable distribution concerned several Husband retirement and investment accounts, a marital residence, and deferred compensation; parties presented competing appraisals and valuations.
- Master recommended a 50/50 division of the marital estate, valued certain accounts at the hearing/distribution date, and denied Wife alimony, counsel fees, and costs; trial court affirmed the master’s report.
- Wife (pro se) challenged valuation methods (Janus‑Vanguard IRA, SERS pension coverture fraction, deferred compensation, and residence), omission of accrued leave, and denial of alimony and fees, arguing disability and economic need.
- Trial court found the marriage short in duration, Wife had been employed through May 2015 with benefits, Wife failed to prove lasting injury or disability, and the court’s valuation approach and 50/50 distribution were appropriate; appellate court affirmed in part and remanded for a minor mathematical correction.
Issues
| Issue | Plaintiff's Argument (Wife) | Defendant's Argument (Husband) | Held |
|---|---|---|---|
| Valuation of IRA and date to value | IRA marital share should be valued at distribution date; Wife claims larger marital portion (62.4%) | Court/master used hearing/distribution date value and calculated marital increase from marriage-to-separation fraction | Court upheld use of hearing date value; found Wife’s 62.4% claim unsupported; corrected minor math error adding ~$54 to marital estate |
| SERS pension coverture fraction | Master miscomputed years of service fraction (small 0.088 difference) altering marital share | Difference is de minimis and does not affect outcome | Court held rounding discrepancy de minimis; no error |
| Deferred compensation valuation | Marital portion should be larger and valued at hearing date (~90% argued) | Master used premarital value subtraction to compute marital portion (72.377%) and applied hearing date | Court accepted master’s method; noted small arithmetic quirk favorable to Wife but de minimis |
| Marital residence valuation | Wife disputed court’s valuation | Parties’ appraisals differed; court averaged the two expert appraisals | Court affirmed averaging of appraisals as reasonable |
| Accrued leave as marital asset | Wife claimed Husband’s accrued leave hours constituted a $15k marital asset | Issue not raised before master; no record evidence/support; waived | Court found claim waived and unsubstantiated |
| Division percentage (50/50) | Wife argued she should receive more due to disability and economic disparity | Court cited short marriage, limited marital estate, Wife’s employment history and other resources | Court upheld 50/50 distribution; no reweighing of statutory factors |
| Alimony, counsel fees, costs | Wife sought alimony and fees based on alleged lasting injury, income disparity, and inability to work | Court found Wife failed to prove lasting injury or disability; Wife had employment history, benefits, and other resources; master considered fee factors | Court affirmed denial of alimony and fees; no abuse of discretion |
Key Cases Cited
- McCoy v. McCoy, 888 A.2d 906 (Pa. Super. 2005) (standard for abuse of discretion review in equitable distribution)
- Biese v. Biese, 979 A.2d 892 (Pa. Super. 2009) (abuse of discretion and weighing statutory factors)
- Hayward v. Hayward, 868 A.2d 554 (Pa. Super. 2005) (objective of equitable distribution is economic justice)
- Morgante v. Morgante, 119 A.3d 382 (Pa. Super. 2015) (trial court credibility findings entitled to deference)
- Baker v. Baker, 861 A.2d 298 (Pa. Super. 2004) (trial court free to accept, reject, or weigh valuation evidence)
- Isralsky v. Isralsky, 824 A.2d 1178 (Pa. Super. 2003) (trial court valuation discretion)
- Smith v. Smith, 653 A.2d 1259 (Pa. Super. 1994) (date of distribution may be appropriate for valuing retirement accounts when no post‑separation contributions)
- Aletto v. Aletto, 537 A.2d 1489 (Pa. Super. 1988) (averaging competing appraisals appropriate)
- Willoughby v. Willoughby, 862 A.2d 654 (Pa. Super. 2004) (review of alimony limited to abuse of discretion)
- Busse v. Busse, 921 A.2d 1248 (Pa. Super. 2007) (court will not reweigh statutory equitable distribution factors)
- Habjan v. Habjan, 73 A.3d 630 (Pa. Super. 2013) (standard for awarding counsel fees and costs in divorce matters)