Sarah R. Bolduc v. Daniel J. Bolduc, 301 A.3d 771

Daniel and Sarah Bolduc married in 2014 and lived in a house in York, Maine that Sarah purchased with her father, William “Mark” Foster, as joint tenants in 2015; Foster provided the $50,000 down payment.
The house served as the marital home; mortgage payments were made from joint marital funds until Daniel left the home in March 2019 and stopped contributing.
Sarah filed for divorce on March 28, 2019; the District Court entered a divorce judgment on March 29, 2022.
The parties introduced competing appraisals: Sarah’s valued the property at $320,000 (March 26, 2019); Daniel’s valued it at $382,500 (October 27, 2021).
The court treated Foster and Sarah as equal joint tenants, found Sarah’s one-half interest was marital property, valued the property at $320,000 (the March 2019 appraisal), computed total equity after mortgage ($178,000) as $142,000, treated marital equity as $71,000 (Sarah’s half) and awarded Daniel $35,500 (half of that).
On appeal the Supreme Judicial Court vacated the portion of the judgment addressing valuation and division of the marital equity, holding the court must value the marital equity as of the date of divorce based on its independent assessment of the appraisal evidence; the remainder of the judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper valuation date for marital property (separation date vs. date of divorce)	Value the property at separation because Daniel vacated then, stopped payments, and Sarah assumed mortgage responsibility.	Value the marital property as of the date of divorce; court must independently assess competing appraisals and use a date proximate to division.	Court erred by valuing at separation; vacated and remanded to value marital equity as of the date of divorce after independent assessment of appraisals.
Treatment of Sarah’s one-half joint-tenancy interest, Foster’s role, and jurisdiction to divide interests	Sarah’s one-half interest (acquired post-marriage) is marital under the statutory presumption and is divisible as her marital property; court may address spouses’ interests though Foster wasn’t a party.	Daniel argued Foster’s joint-tenancy share could be altered by subsequent contributions and contended the court lacked authority to determine Foster’s interest.	Court correctly classified Sarah’s one-half interest as marital and had jurisdiction to divide the spouses’ marital interests; Foster’s nonmarital half was not part of the marital estate and the court could not dispose of Foster’s separate interest. The court also found Daniel offered no proof that his renovations increased value.

Findlen v. Findlen, 695 A.2d 1216 (Me. 1997) (court must independently assess competing appraisals when valuing marital property)
Shirley v. Shirley, 482 A.2d 845 (Me. 1984) (court may rely on a more recent appraisal only after independent evaluation)
Crooker v. Crooker, 432 A.2d 1293 (Me. 1981) (value of marital assets should be determined as of the time they are distributed)
Austin v. Austin, 748 A.2d 996 (Me. 2000) (error to fix valuation date inconsistent with actual division of the asset)
Ackerman v. Hojnowski, 804 A.2d 412 (Me. 2002) (when dividing joint-tenancy property, court should consider post-acquisition contributions and all equities)
Bradford v. Dumond, 675 A.2d 957 (Me. 1996) (joint tenants generally hold equal undivided interests absent evidence to the contrary)
Moran v. Moran, 279 A.3d 385 (Me. 2022) (court erred valuing property at de facto separation rather than at divorce when that implicitly treated later increases as nonmarital)
Laqualia v. Laqualia, 30 A.3d 838 (Me. 2011) (standards of review and three-step process for equitable distribution of marital property)