McBride v. Worth

Summary

The Maine Supreme Judicial Court reviewed post-divorce enforcement proceedings involving spousal-support arrears, refinancing of the marital home, and attorney fees. The court held that using income withholding to enforce the arrears was within the trial court's discretion, but vacated the income withholding order and partially vacated the judgment because the payment provisions were inconsistent and unclear. The court affirmed the refinancing directive and the partial award of attorney fees.

Holdings

1. A court may enforce spousal-support arrears through installment payments or an income-withholding order instead of requiring immediate lump-sum payment, and the District Court did not abuse its discretion in selecting income withholding here.
2. The judgment and income-withholding order had to be partially vacated because they misstated the amount of ongoing weekly support and failed to make clear what additional amount was intended to be withheld toward the arrears.
3. When a divorce judgment provision is ambiguous, the trial court has inherent authority to construe and clarify it, and the District Court reasonably clarified the refinancing provision by requiring McBride to apply for refinancing every six months while Worth continued regular support payments.
4. The District Court did not abuse its discretion by awarding McBride approximately sixty percent of the attorney fees she requested rather than the full amount.

Questions Presented

1. Whether the District Court abused its discretion by enforcing spousal-support arrears through an income-withholding order rather than ordering immediate lump-sum payment.
2. Whether the District Court properly clarified the ambiguous refinancing provision in the divorce judgment by requiring McBride to apply for refinancing every six months.
3. Whether the District Court abused its discretion by awarding McBride only $5,000 of her requested attorney fees.

Disposition

vacated