Stevens v. Stevens, 265 P.3d 279

Ronald and Sharon Stevens separated in August 2006 after a 40-year marriage.
A June 2007 superior court trial yielded partial settlement on property; no written agreement.
A second trial day occurred August 6, 2008; court valued property as of June 8, 2007.
Court valued two homes and split retirement income; ordered each party to pay own attorney's fees.
Appeals challenged (Stevens) the valuation date and (Stevens) other property-distribution aspects.
Court reversed valuation date ruling and remanded; other property-division aspects affirmed or remanded as needed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether valuation should use the later trial date rather than the first.	Stevens argues later date reflects most current values	Stevens argues earlier date avoids windfall from failed settlement	Yes; use later date on remand for current values
Whether vehicles should follow the blind bidding results.	Ronald contends he bid on vehicles; should get both	Sharon crossed vehicles off as undisputed; non-biddable finding supports result	No clear abuse; remand allows current valuation evidence
Whether $10,000 interim spousal support should be treated as marital property.	Stevens argues it should be treated as marital property credit	Support award recharacterization permissible	Not an abuse; court reasonably recharacterized as part of estate distribution
Whether equal division was appropriate given health and earning disparities.	Stevens seeks greater share due to health and income gap	Court found equal division appropriate given similar risks and retirement split	Remand for new valuation may alter distribution; no final error found here
Whether attorney's fees were properly denied.	Stevens argues fees should be awarded based on income disparity	Fees allowed by TSP/assets sufficiency; court acted within discretion	Not an abuse; remand may reevaluate with new valuations

Ogard v. Ogard, 808 P.2d 815 (Alaska 1991) (valuation date should be near trial; exceptions limited)
Cox v. Cox, 882 P.2d 909 (Alaska 1994) (separation vs. trial date; seek most current information)
Heustess v. Kelley-Heustess, 813 P.2d 674 (Alaska 1991) (exception to Ogard for deceptive conduct; later cases follow general rule)
Adrian v. Adrian, ? (Alaska unknown) (Alaska) (emphasized income figure reflects economic reality (context))
Foster v. Foster, 883 P.2d 397 (Alaska 1994) (valuation and division guidance)
Brown v. Brown, 914 P.2d 206 (Alaska 1996) (valuation relevance; equity considerations)
Lacher v. Lacher, 993 P.2d 413 (Alaska 1999) (guidance on valuation and distribution)
Notkin v. Notkin, 921 P.2d 1109 (Alaska 1996) (contextual valuation principles)