## Facts

- Steven Michael Gust and Linda Leann Gust married in 1985 and dissolved their marriage after approximately 27 years.
- Throughout most of the marriage, Steven worked full-time as the primary wage earner, while Linda primarily performed homemaking and child-care responsibilities and later worked in low-wage employment.
- At trial, Steven’s earning capacity was approximately $92,000 annually and Linda’s was approximately $22,500 annually.
- The district court divided marital property and debts approximately equally, rejected a dissipation claim, and declined to award Linda trial attorney fees.
- The district court awarded Linda traditional spousal support of $1,400 per month while Steven owed child support for the parties’ minor son, increasing to $2,000 per month thereafter for an unlimited duration.
- Steven sought a post-trial reduction and a retirement-based termination date; the district court denied the requested changes.
- The court of appeals affirmed; on further review, the supreme court limited its review to the spousal support award.

## Issues

1. Whether the award of traditional spousal support of $2,000 per month for an unlimited duration was fair and equitable under Iowa Code § 598.21A.
2. Whether the decree was required to account for Steven’s future retirement by setting an automatic reduction or termination of spousal support, rather than leaving retirement to a later modification action.

## Decision

- The Iowa Supreme Court affirmed the court of appeals and the district court on the spousal support issues.
- The court held the $2,000 per month traditional spousal support award of unlimited duration was fair and equitable on these facts.
- The court held the district court did not err by declining to build a prospective retirement-based adjustment into the original decree.
- The court left any retirement-related change to be addressed in a future modification proceeding when retirement is imminent or has occurred.

## Legal Principles

- Traditional spousal support may be appropriate for long-term marriages where marital roles contributed to a substantial disparity in earning capacities and the dependent spouse cannot reasonably attain a comparable standard of living through earnings alone.
- Spousal support determinations are guided by Iowa Code § 598.21A factors, including length of the marriage, ages of the parties, earning capacities, and contributions to the marriage (including homemaking and child care).
- An equal property division does not necessarily eliminate the need for traditional spousal support when significant post-dissolution income disparity remains.
- Courts may modify spousal support upon a substantial change in circumstances; retirement-related arguments are commonly addressed through modification when the retirement’s timing and financial impact are concrete rather than speculative.

## Conclusion

The court upheld lifetime traditional spousal support after a long marriage with a marked earning-capacity disparity shaped by marital roles, and it held that anticipated retirement should be evaluated in a later modification action rather than predetermined in the dissolution decree.


In re Marriage of Gust, 858 N.W.2d 402 (Iowa 2015)