## Facts

- Jeffrey Crider (husband) and Christina Crider (wife) married in 1992 and had two children; one child was emancipated by the decree.
- Wife filed for dissolution in May 2009 after earlier dismissed actions.
- The marital estate was substantial and largely illiquid, consisting mainly of husband’s interests in closely held family businesses, including a significant shareholding in Crider & Crider, Inc. (CCI) and membership interests in related LLCs.
- The parties presented conflicting expert evidence on the value of CCI’s equipment (wife’s expert substantially higher than husband’s expert).
- The trial court valued key business assets within the range of the evidence, divided marital property equally, and entered a large cash equalization judgment in wife’s favor ($4,752,066), with statutory post-judgment interest.
- To secure payment, the decree imposed security provisions tied to husband’s stock and LLC interests and contemplated changes in control if payment was not made within 180 days.
- Husband did not pay within the specified period, and the trial court entered post-judgment enforcement orders (including liens, attachment, and garnishment-type relief).
- Husband appealed both the dissolution decree and enforcement orders; certain business entities intervened, asserting that some relief improperly affected entity governance or assets.

## Issues

1. Whether the trial court’s valuation of husband’s closely held business interests was clearly erroneous in light of conflicting expert testimony.
2. Whether the equalization judgment and related interest provisions were permissible given the estate’s illiquid composition.
3. Whether awarding wife attorney’s fees tied to enforcement of the decree was within the trial court’s authority.
4. Whether the decree’s security provisions—particularly any automatic vesting or transfer of corporate/LLC ownership or control upon nonpayment—exceeded statutory authority or improperly affected third-party/entity rights.
5. Whether the trial court properly treated alleged obligations to husband’s father as non-marital debt.
6. Whether child-support adjustments and later modifications were supported by proper findings and procedure.
7. Whether post-judgment enforcement measures (continuing liens, attachment of future proceeds, garnishment/withholding orders) were authorized and sufficiently limited.

## Decision

- The Court of Appeals affirmed in part, reversed in part, and remanded.
- It affirmed the core property division framework and the cash equalization judgment as a permissible means of balancing an otherwise equitable distribution of illiquid assets.
- It affirmed valuation determinations where the trial court selected values supported by evidence and within the range of expert testimony.
- It upheld, in general, the trial court’s ability to award dissolution-related attorney’s fees, including fees connected to enforcement, while requiring correction of aspects that were overbroad.
- It reversed portions of the security and enforcement structure to the extent the orders exceeded dissolution or judgment-enforcement authority or improperly interfered with corporate/LLC governance and nonparty rights, and remanded for restructuring.
- It affirmed the trial court’s rejection of claimed “loans” as marital debt where the record supported the conclusion they were not genuine enforceable obligations.
- It remanded aspects of child-support rulings and certain enforcement orders for clarification, recalculation, or narrowing consistent with statutory limits.

## Legal Principles

- Trial courts have broad discretion in dividing marital property, but remedies must remain within statutory authority and cannot disregard the rights of nonparties and business entities.
- When experts conflict on valuation, a trial court may adopt a value supported by the record and within the evidentiary range; appellate review does not reweigh evidence or reassess credibility.
- A cash equalization judgment is an accepted tool to achieve an equitable division where marital assets are illiquid.
- Attorney’s fees may be awarded in dissolution matters to address financial disparity and to ensure access to judicial relief; fee orders must be properly bounded and supported.
- A court may employ liens or security interests to secure payment of a dissolution judgment, but it may not structure security so that it effectively forces an ownership/control shift in closely held entities in a manner that conflicts with statutory enforcement mechanisms or interferes with entity governance and third-party rights.
- Claimed marital debts may be excluded where the factfinder reasonably concludes the obligation lacks credible indicia of a true loan (such as documentation and repayment terms).
- Judgment-enforcement devices (including garnishment and attachment-type orders) must comply with governing statutes and due-process requirements and should not operate as open-ended encumbrances beyond lawful limits.

## Conclusion

The appellate court largely upheld the equal division and equalization judgment in a high-asset dissolution involving illiquid closely held business interests, but required modification of security and enforcement provisions that went beyond authorized judgment-enforcement tools or intruded on corporate/LLC governance and nonparty rights, remanding for orders consistent with statutory limits.


Crider v. Crider, Nos. 53A05-1307-DR-358 & 53A04-1401-DR-26 (Ind. Ct. App. Aug. 26, 2014)