Summary
The Iowa Supreme Court affirmed an indefinite traditional spousal-support award requiring Steven Gust to pay $1,400 per month, increasing to $2,000 per month after child support ended. The court reviewed Iowa’s statutory factors governing spousal support, including marriage duration, earning capacity, need, ability to pay, property division, and the feasibility of self-support. The court limited further review to spousal support and affirmed the remaining rulings concerning property division and attorney fees.
Holdings
- The award of $1,400 per month while child support was payable and $2,000 per month thereafter for life was equitable under Iowa's multifactor statutory framework.
- Prospective retirement ordinarily presents too many speculative issues to be resolved in the initial spousal-support award; its effect must be addressed in a later modification action when retirement is imminent or has occurred.
- The district court's rulings on the property division, dissipation-of-assets claim, and attorney-fee issues, as affirmed by the court of appeals, remain affirmed because further review was limited to spousal support.
Questions Presented
- Whether the award of traditional spousal support of $1,400 per month while child support was payable and $2,000 per month thereafter was equitable under Iowa Code section 598.21A(1).
- Whether the district court should have limited or reduced the initial spousal-support award based on Steven's prospective retirement.
- Whether the court of appeals and district court rulings on the other issues raised by the parties should be affirmed.
Disposition
affirmed
Cases Cited (23)
- In re Marriage of Schenkelberg, 824 N.W.2d 481 (Iowa 2012)(followed)
- In re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005)(followed)
- In re Marriage of Spiegel, 553 N.W.2d 309 (Iowa 1996)(followed)
- In re Marriage of Benson, 545 N.W.2d 252 (Iowa 1996)(followed)
- Schantz v. Schantz, 163 N.W.2d 398 (Iowa 1968)(followed)
- In re Marriage of Williams, 199 N.W.2d 339 (Iowa 1972)(followed)
- In re Marriage of Becker, 756 N.W.2d 822 (Iowa 2008)(followed)
- In re Marriage of Francis, 442 N.W.2d 59 (Iowa 1989)(followed)
- In re Marriage of Michael, 839 N.W.2d 630 (Iowa 2013)(followed)
- In re Marriage of Geil, 509 N.W.2d 738 (Iowa 1993)(followed)
Showing top 10 of 23.
Cited In (0)
No citing cases on record yet.
Court Document
Open PDFLoading document…