Robert A. Masters v. Leah Masters
43 N.E.3d 570
| Ind. | 2015Background
- Parties married in 1993; one daughter born 2007. Dissolution proceedings began in 2012; parties agreed to arbitrate under Indiana's Family Law Arbitration Act (FLAA).
- Arbitrator issued detailed written findings and conclusions addressing custody, support, property division (60% to wife, 40% to husband), coins/appraisals, spousal maintenance, and attorney's fees.
- Arbitrator ordered husband to pay $95,000 of wife's attorney's fees; trial court entered judgment on the arbitration award under Ind. Code § 34-57-5-7(d)(1).
- Husband appealed only the attorney-fee award, arguing it was against the logic and effect of the facts and that he could not pay it; Court of Appeals reversed and remanded the fee award as clearly erroneous.
- Indiana Supreme Court granted transfer to decide (1) the proper standard of appellate review for FLAA awards and (2) whether the $95,000 fee award was supported by the arbitrator’s findings.
- Supreme Court affirmed: held FLAA awards reviewed under the same standard as trial-court dissolution decisions with findings (Trial Rule 52(A): clearly erroneous), and the fee award was supported by the findings (husband’s property share, including coins, exceeded $215,000).
Issues
| Issue | Appellant (Masters) Argument | Appellee (Leah) Argument | Held |
|---|---|---|---|
| Proper standard of appellate review for FLAA awards | Apply narrow, highly deferential UAA-style review or remand for trial-court hearing on fees | Apply same standard as review of trial-court dissolution decisions (deferential but not UAA-narrow) | FLAA awards reviewed under same standard as trial-court dissolution decisions with findings—Trial Rule 52(A) clearly erroneous standard |
| Whether $95,000 attorney-fee award was supported by findings | Fee award is against logic/effect of facts; husband cannot pay given his asserted ~$94,000 property share; arbitrator ignored wife’s potential income and fee funding by her parents | Arbitrator considered assets, incomes, coins appraisal, funding, and awarded fees within discretion | Fee award supported by findings; not clearly erroneous; affirmed |
| Whether husband's inability-to-pay claim or alleged contradictions in findings require reversal | Husband lacked ability to pay; fees disproportionate to result and his actual net share | Arbitrator considered ability to pay, property division (including coins), funding sources, discounted counsel rates for husband | Husband received >$215,000 in marital property (including coins); record supports fee award; no reweighing of evidence; affirm |
Key Cases Cited
- Quillen v. Quillen, 671 N.E.2d 98 (Ind. 1996) (applies clearly erroneous standard to review of attorney's-fee awards in dissolution cases)
- Egly v. Blackford Cnty. Dep't of Pub. Welfare, 592 N.E.2d 1232 (Ind. 1992) (defines "clear error" standard)
- Weigel v. Weigel, 24 N.E.3d 1007 (Ind. Ct. App. 2015) (describes two-tier review of findings then judgment)
- Yoon v. Yoon, 711 N.E.2d 1265 (Ind. 1999) (appellate court will not reweigh evidence and must view evidence favorable to judgment)
- Ozug v. Ozug, 4 N.E.3d 827 (Ind. Ct. App. 2014) (Court of Appeals vacated FLAA award for insufficient findings; discussed comparative review approaches)