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Where trial court fails to make specific findings in determining property division, but division is equitable, divorce judgment is affirmed

The court held that while the trial court erred when it did not make specific findings as to the relevant Sparks factors, the error was harmless. In light of the totality of the circumstances, the court was not left with a firm conviction that the property division was inequitable. The trial court also erred in failing to make findings as to the relevant spousal support factors, but the court again held that the error was harmless given that the "spousal support award was just and reasonable under the circumstances." The trial court did not abuse its discretion in denying the defendant-wife's request for attorney fees. Thus, the court affirmed the judgment of divorce. The trial court "considered some of the Sparks factors in its opinion" and its "division of property was equitable under the circumstances." The trial court noted the "duration of the parties' marriage and considered that both parties contributed to the marital estate and were devoted to the farm and the horses." It considered "the age, health and life situation of the parties, noting that defendant had no independent income source, but would qualify for Social Security benefits" in 2014 in the amount of either $650 or $740 per month. It considered that the plaintiff-husband "enjoyed a pension and Social Security benefits in the amount of $2,296 per month. Based on comments at the trial and language in the judgment of divorce," the trial court "was aware that both parties stipulated to split the liquid assets of the estate, each receiving $107,000." It also considered that "plaintiff lived at the farm for 21 years before the parties were married. This factor was significant" in its determination "that it was equitable to award the farm to plaintiff, while awarding defendant one-half of the appraised value of the farm for her continued support." The trial court also took into account the parties' conduct. In particular, it "noted that defendant left the farmhouse in a 'stripped condition' resulting in plaintiff's loss of many of his personal items." Defendant argued that the trial court "left her with no means of earning a living when it awarded the farm to plaintiff. However, the evidence does not support this assertion. At trial defendant testified that she had not given riding lessons for the previous two years and testimony showed that the farm never earned a profit." As to spousal support, the court concluded that the trial court's award of $450 per month was just and reasonable considering the circumstances. It was "not left with a firm conviction" that the spousal support award was inequitable.


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