## Facts

- Thomas and Diana Francis married shortly after Thomas was admitted to medical school.
- During the approximately six-year marriage, Thomas completed medical school and obtained an M.D.
- Diana operated an in-home day-care business earning about $5,000 annually and reduced her own career opportunities while supporting the household.
- The couple largely lived on a $45,000 student loan used for Thomas’s schooling and living expenses.
- At dissolution trial, Diana offered expert testimony attributing a portion of Thomas’s future increased physician earnings to an educational “capital investment,” and valuing Diana’s claimed share of that increase at approximately $121,279.
- The trial court awarded Diana a $100,000 lump-sum award labeled as a property award, plus several years of rehabilitative alimony.
- Thomas appealed, arguing that a medical degree and its future earning capacity are not divisible property and that the valuation method was speculative and excessive.

## Issues

1. Whether a professional degree or the enhanced earning capacity associated with it is marital “property” subject to division at dissolution.
2. Whether, and in what form, a supporting spouse may be compensated for economic sacrifices that enabled the other spouse to obtain a professional education during the marriage.
3. Whether expert-based valuation of enhanced earning capacity was impermissibly speculative such that the lump-sum award could not stand.

## Decision

- The Iowa Supreme Court affirmed the dissolution decree as modified.
- The court held the medical degree itself is not marital property subject to division.
- The court held enhanced earning capacity resulting from the degree may be considered to reach an equitable result, particularly where the marriage ends shortly after the degree is obtained and the expected financial return lies mainly in the future.
- The court approved compensating Diana for her contributions but recharacterized the $100,000 lump-sum “property” award as reimbursement alimony.
- The court preserved but modestly adjusted the rehabilitative alimony to support Diana’s efforts toward further training.

## Legal Principles

- A professional degree is not divisible marital property because it is personal to the holder and not transferable or marketable as an asset.
- Enhanced earning capacity attributable to education obtained during marriage may be considered in crafting equitable financial relief at dissolution.
- Reimbursement alimony is an appropriate mechanism to compensate a spouse who made economic sacrifices that financed or facilitated the other spouse’s education or training; it is compensatory rather than strictly need-based.
- Courts are not limited to repayment of out-of-pocket educational costs; an award may reflect a fair share of the economic benefit expected from the education, even though future earnings projections involve uncertainty.
- Appellate equitable review permits modification of the form and amount of relief to better match the proper legal characterization and equitable objectives.

## Conclusion

The court refused to treat a medical degree as divisible property but allowed compensation tied to the degree’s economic consequences, using reimbursement alimony to repay the supporting spouse for marital sacrifices that enabled the education and to avoid an inequitable allocation of the degree’s future financial benefits.


In re Marriage of Francis, 442 N.W.2d 59 (Iowa 1989)