Seanneen Brown v. Lawrence Herman Brown, 327826

Parties married in 1990; four children (one minor at trial). Defendant (age 50) employed by State of Michigan earning about $72,000/year; plaintiff (age 46) left workforce to raise children, later enrolled in accelerated nursing program and had part‑time substitute work history.
Marital assets included the family home (trial value $175,000) subject to two mortgages (~$169,402 remaining), a vacant lot (disputed value), vehicles (plaintiff: Town & Country van purchased for $14,500; defendant: inoperable car and motorcycle), and personal property (including a riding lawnmower).
Plaintiff filed bankruptcy discharging >$28,000 in credit‑card debt and listed lower values for the home and lot on the bankruptcy petition; plaintiff also had ~ $30,000 in student loans (court attributed those loans to her).
Trial court awarded the marital home, lot, mortgages, and credit‑card debt to defendant; awarded the van and no marital debt to plaintiff; adjusted personal property allocations and allocated Lesko benefits to defendant.
Trial court reduced spousal support to $800/month for Feb–Sept 2015 (transitional support), and ordered child support recalculated with income imputed to plaintiff for 20 hours/week at minimum wage; defendant ordered to pay $860/month child support.
Plaintiff appealed, challenging property distribution, spousal support amount/duration, and imputation of income for child support. Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Equity of property division	Award was inequitable; court misattributed certain debts/values (student loans, lot valuation).	Distribution properly considered contributions, debts, bankruptcy filings, and defendant’s mortgage/tax payments.	Affirmed: trial court’s factual findings not clearly erroneous; division not inequitable.
Valuation of specific assets (student loans, van, lot)	Court should have treated some student‑aid and loans as marital debt; lot worth $20,000; van valuation challenged.	Bankruptcy filings and credibility favored lower values; van valued at actual payoff price.	Affirmed: court credited defendant’s valuations and plaintiff’s bankruptcy statements; no clear error.
Spousal support amount/duration	Requested longer, larger non‑modifiable support to cover schooling and adult children support.	If awarded, support should be minimal, modifiable, short.	Affirmed: $800/month for 8 months was reasonable transitional support; court considered relevant Olson factors.
Imputation of income for child support	Plaintiff’s nursing program schedule precluded 20 hrs/week; court lacked evidence for imputation.	Plaintiff could work part‑time; minimum‑wage, 20‑hour imputation was practical and supported by testimony.	Affirmed: imputation to part‑time minimum‑wage employment was supported by findings and not clearly erroneous.

Sparks v. Sparks, 440 Mich. 141 (equitable distribution standard; appellate review of dispositional rulings)
Richards v. Richards, 310 Mich. App. 683 (deference to trial court credibility findings)
Gates v. Gates, 256 Mich. App. 420 (goal of equitable marital distribution)
Berger v. Berger, 277 Mich. App. 700 (purpose of spousal support balancing incomes and needs)
Olson v. Olson, 256 Mich. App. 619 (factors to consider in awarding spousal support)
Stallworth v. Stallworth, 275 Mich. App. 282 (standards and factors for imputing income for child support)
Lesko v. Lesko, 184 Mich. App. 395 (Lesko benefits and treatment of banked leave days as marital asset)