W.R. v. C.R., 75 So. 3d 159

W.R. and C.R. married in 1998 and have one biological child; in 2008 they adopted four siblings under the Alabama Subsidized Adoption Act with a monthly subsidy of $2,437.50.
The couple owned and transferred between multiple properties; mortgage activity included paying down debts with settlement proceeds and mortgage payoff by 2007, then a line of credit of about $160,000 secured by the Mobile property.
They separated in December 2008; mother and children remained in the marital residence while father moved to the Mobile property, and mother sought a divorce in February 2009.
Pendente lite orders granted mother custody with visitation for father; later orders adjusted visitation to supervised and alternating weekends.
Trial in December 2009 led to a final judgment on February 22, 2010: joint legal custody, mother primary physical custody, father had visitation, child support set at $817 monthly; real-property division favored the mother with the marital residence, father received the Mobile property, and debts were allocated.
The court reserved alimony; mother's attorney was awarded $1,000; appeal followed by the father challenging property division, child support offset for adoption subsidy, potential deviations from guidelines, and attorney’s-fee award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the property division was equitable.	W.R. contends the trial court erred by giving the mother the equity in the marital residence and awarding him the encumbered Mobile property.	C.R. argues the court properly considered multiple factors and did not abuse discretion; division was equitable in light of assets and debts.	Equitable, not an abuse of discretion.
Whether adoption subsidy offsets child support.	W.R. seeks to credit half of the subsidy against his child-support obligation for the adopted children.	C.R. asserts the subsidy is for the child and does not offset parental income, citing case law upholding supplementation, not replacement.	Adoption subsidy is not offset against child support; it is supplemental.
Whether downward deviation from guidelines was warranted.	W.R. argues deviation is appropriate given his income and the children's special needs expenses.	C.R. contends guidelines should apply; deviation requires manifest injustice, which the court did not find.	No abuse of discretion; guidelines applied.
Whether the attorney's-fee award to the mother was proper.	W.R. challenges the fee as excessive given the circumstances and equity.	C.R. argues fee appropriate considering conduct and financials; not excessive.	Court did not exceed discretion; $1,000 affirmed.

Baggett v. Baggett, 855 So.2d 556 (Ala. Civ. App. 2003) (property division and alimony interrelated; equity standard governs, not equal division)
Lightel v. Myers, 791 So.2d 955 (Ala. Civ. App. 2000) (adoption subsidy is not offset as substitute income; remains for child support)
Ex parte Elliott, 782 So.2d 308 (Ala. 2000) (factors for equitable division; includes conduct and circumstances)
Golden v. Golden, 710 So.2d 924 (Ala. Civ. App. 1998) (trial court may deviate from guidelines when manifestly unjust or inequitable)