## Facts

- Audra Marian Guy and Robert Sidney Guy, Jr. married in 1994, separated in 1997, and divorced on irreconcilable differences in 1997.
- During the marriage, Rob worked and supported the household while Audra pursued and obtained a nursing degree.
- In the divorce judgment, the chancellor valued Audra’s nursing degree at $35,000 based on Rob’s testimony about amounts spent supporting Audra during school.
- The chancellor treated the $35,000 as part of the marital estate by crediting that amount to Audra’s side of the equitable distribution.
- Audra’s post-judgment motion to alter or amend (or for relief from judgment) was denied, and she appealed.

## Issues

1. Whether a professional degree earned during marriage constitutes marital property subject to equitable distribution.
2. If a professional degree is not marital property, whether and how the supporting spouse may be compensated for contributions to the other spouse’s education.
3. Whether the chancellor erred by valuing the degree at $35,000 and allocating that amount through property division.

## Decision

- The Supreme Court of Mississippi held that a professional degree is not marital property and cannot be assigned a dollar value and divided as a marital asset.
- The court recognized that a supporting spouse may be compensated through reimbursement alimony for contributions made to the other spouse’s education and increased earning capacity.
- The court reversed the chancery court’s treatment of the nursing degree as a $35,000 marital asset.
- The court remanded for consideration of reimbursement alimony consistent with its opinion.

## Legal Principles

- Marital property subject to equitable distribution does not include a professional degree because it is personal to the holder, nontransferable, and not reliably valued as a present asset.
- A spouse’s contributions to the other spouse’s education may be considered in equitable decision-making, but those contributions do not convert the degree into divisible property.
- Alimony and equitable distribution are distinct remedies; education-related contributions may be addressed through reimbursement alimony rather than by placing a degree on the marital balance sheet.
- Reimbursement alimony may compensate a spouse for financial support and contributions that enabled the other spouse to obtain education or training that increases earning capacity, particularly when the marriage ends before the supporting spouse benefits from that increased capacity.

## Conclusion

The court rejected classifying and valuing a professional degree as marital property, but allowed a supporting spouse to seek reimbursement alimony for proven contributions to the other spouse’s education, reversing the property-division approach and remanding for reconsideration under an alimony framework.


Guy v. Guy, 736 So. 2d 1042 (Miss. 1999)