Divorce; Marital home valuation; Property division; Sparks v Sparks; Dissipation of marital assets; Elahham v Al-Jabban; Interest on property awards; Reigle v Reigle; Fault; Extramarital affairs; Spousal support; Child support income

The court held that the trial court erred by awarding defendant reimbursement for dissipated assets and abused its discretion by awarding interest, but otherwise affirmed the divorce judgment. Plaintiff challenged the valuation of the marital home, the dissipation finding, interest award, fault allocation, and spousal support. The court first held that the marital-home valuation was not clear error because the trial court chose a value “within the range established by the proofs,” relied on the 1/24 appraisal as the most recent available valuation, and gave the parties a chance to submit updated appraisals before judgment. The court next held that the dissipation finding was erroneous because the trial court did not find plaintiff spent funds “wastefully or foolishly,” plaintiff provided for defendant and the children, and spending on food, entertainment, records, and family gifts was “part of plaintiff’s normal spending pattern.” The court also held that interest on certain property awards had to be vacated because interest in a divorce action is equitable, but the trial court “did not explain why it was equitable,” and plaintiff’s payments were not delinquent when judgment entered. The court rejected plaintiff’s fault challenge because the trial court considered the Sparks factors, then found fault based on plaintiff’s affairs, and the record did not show the court placed “excessive weight” on fault. Finally, the court upheld spousal support because the trial court made findings under the proper factors, recognized that much of defendant’s property award was not income-producing, and plaintiff cited no authority requiring child support to be counted as income for spousal-support purposes. Interest award vacated, dissipated-assets award reversed, and otherwise affirmed.