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In re the Marriage of Snyder

Citation: Not availableDocket: 22-0080

Court: Court of Appeals of Iowa; November 16, 2022; Iowa; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves an appeal from Jodi Jean Snyder challenging the equitable distribution of marital assets and debts following the dissolution of her marriage to Adam Jeffery Snyder. The Iowa District Court initially ordered Adam to make an equalization payment to Jodi, which she contested, arguing improper accounting of temporary support payments and asset dissipation by Adam. The appellate court reviewed the case de novo, assessing issues such as credibility determinations and the preservation of claims for appeal. The court found that Adam failed to justify post-separation credit card debts, constituting asset dissipation, and adjusted the asset division accordingly, increasing Adam's payment obligation to Jodi. The court also addressed the issue of attorney fees, denying Jodi's request for trial fees but granting her a portion of appellate fees due to her partial success and financial need. The decision was affirmed in part and modified, with the case remanded for further proceedings regarding appellate attorney fees and the recalculated equalization payment. Costs of the appeal were apportioned between the parties, reflecting their respective successes and financial capabilities.

Legal Issues Addressed

Attorney Fees in Family Law Appeals

Application: Jodi was granted one-third of her appellate attorney fees from Adam, as she partially succeeded on appeal and demonstrated a greater need for financial assistance.

Reasoning: Although Jodi's appeal was only partially successful, it had merit and resulted in a favorable modification.

Credibility Determinations in Family Law

Application: The court accepted Adam's testimony regarding double payments as credible, affecting the asset division in Jodi's column.

Reasoning: The district court accepted Adam's testimony regarding this issue as credible and included the $6,633.00 as an asset in Jodi’s column on the recapitulation statement.

Dissipation of Marital Assets

Application: The court found that Adam engaged in dissipation by incurring credit card debts without proving they were for legitimate expenses, leading to an adjustment in the division of assets.

Reasoning: Upon de novo review, it was concluded that Adam engaged in dissipation by incurring credit card debts without proving they were for legitimate expenses.

Equitable Distribution of Marital Assets

Application: The court adjusted the asset division to ensure equitable distribution after considering the net worth disparity, resulting in an increased equalization payment from Adam to Jodi.

Reasoning: To achieve an equitable distribution, Adam was ordered to pay Jodi an equalization payment of $9,863.50.

Preservation of Issues for Appeal

Application: Jodi's claim regarding dissipated assets was not preserved for appeal because it was not properly raised before the district court.

Reasoning: However, this issue was not preserved for appeal since Jodi did not properly raise it before the district court.