Schulte v. Kramer

Summary

The North Dakota Supreme Court reviewed the termination of Kenneth Kramer's obligations to pay spousal support, provide health insurance, and pay non-covered medical expenses under a divorce judgment. The court held that the reduction in Kramer's income was self-induced and that the district court applied an erroneous legal standard in eliminating spousal support. It affirmed that the health-insurance and medical-expense obligations constituted spousal support, reversed the termination of those obligations, and remanded for further proceedings, including consideration of attorney's fees.

Holdings

1. Although the income reduction constituted a material change in circumstances, the district court erred by concluding that the reduction was not self-induced merely because Kramer did not foresee that his misconduct would result in termination. Because Kramer's voluntary and knowing conduct caused the income reduction, the court was required to determine whether a substantial showing of good faith or valid cause nevertheless justified modification, and it was required to reconsider the amount of support rather than automatically eliminate it.
2. The obligation to provide Schulte's health insurance and pay non-covered medical expenses was spousal support rather than property division.
3. The district court erred in denying or failing to resolve Schulte's request for attorney's fees without specific findings addressing the parties' financial conditions, needs, and ability to pay.

Questions Presented

1. Whether the district court clearly erred or applied an erroneous legal standard in eliminating Kramer's stipulated spousal-support obligation after his income declined following termination from employment.
2. Whether the obligations to provide health insurance and pay non-covered medical expenses were spousal support or property-division obligations.
3. Whether the district court erred by denying Schulte's request for attorney's fees without making specific findings under N.D.C.C. § 14-05-23.

Disposition

reversed_and_remanded