## Facts

- Jeannine Marie Grosskopf and Loren M. Grosskopf married in 1968 while both were college students.
- Jeannine completed a degree in special education and worked full time during periods when Loren was finishing college and later pursuing a master’s degree in accounting at the University of Wyoming.
- The parties moved to Wyoming, established a home in Cody, and had three children (ages 11, 5, and 2 at the time of divorce).
- After about twelve years, marital difficulties intensified; evidence supported findings that Jeannine was unhappy in Wyoming, became celibate for several years, and often threatened to leave.
- Loren filed for divorce in 1980; Jeannine left for Wisconsin with the children, later returning for an unsuccessful reconciliation attempt.
- The trial court granted Loren a divorce, found Jeannine more at fault, awarded Jeannine custody with child support, split liquid assets equally, assigned all marital debts to Loren, and denied Jeannine alimony and attorney’s fees.

## Issues

1. Whether the trial court erred in finding Jeannine more at fault and granting Loren the divorce on that basis.
2. Whether the trial court abused its discretion by considering marital fault in property division, alimony, and child support under Wyo. Stat. § 20-2-114 (1977).
3. Whether Loren’s master’s degree and increased earning capacity constitute divisible “property,” or require other equitable compensation to Jeannine for her educational contributions.
4. Whether denial of alimony and the amount of child support constituted an abuse of discretion.
5. Whether the trial court erred in denying Jeannine attorney’s fees.

## Decision

- Affirmed the district court in all respects.
- Held sufficient evidence supported the trial court’s finding that Jeannine was more at fault in the marital breakdown.
- Held the trial court could consider fault as one factor in crafting a “just and equitable” property division and in deciding alimony and child support.
- Held an educational degree and the resulting increased earning capacity are not “property” divisible under § 20-2-114.
- Held denial of alimony, the child support award, and denial of attorney’s fees were within the trial court’s discretion given the parties’ circumstances and the overall distribution (including Loren’s assumption of all marital debts).

## Legal Principles

- Appellate review of divorce decrees is deferential; findings on fault and economic orders will be upheld absent clear error or abuse of discretion.
- Under Wyo. Stat. § 20-2-114, the court must make a “just and equitable” disposition; marital fault may be considered among multiple factors unless prohibited by statute.
- Educational degrees, professional training, and increased earning capacity are not divisible marital “property” because they are not transferable assets; a supporting spouse’s contributions may be addressed indirectly through the overall equitable distribution and support orders.
- Alimony and attorney’s fees are discretionary; employability, property received, and comparative financial burdens (including marital debts) are relevant to whether an award is warranted.

## Conclusion

The Wyoming Supreme Court affirmed the divorce decree, approving the trial court’s consideration of fault in equitable economic orders and rejecting treatment of a spouse’s educational degree and enhanced earning capacity as divisible property, while finding no abuse of discretion in the property division, support determinations, or denial of alimony and attorney’s fees.


Grosskopf v. Grosskopf, 677 P.2d 814 (Wyo. 1984)