## Facts

- Gordon D. Haugan (husband) and Patricia J. Haugan (wife) married in August 1973.
- Shortly after the marriage, Gordon entered medical school; Patricia worked full time as a teacher and substantially supported the household during his schooling.
- During medical school, Patricia’s earnings supported the couple while Gordon had minimal income and relied on loans and a small stipend.
- During Gordon’s residency, both parties worked, but Patricia continued significant financial support and performed virtually all household duties.
- In 1980 the couple purchased a home in Green Bay in anticipation of Gordon’s medical practice; Patricia resigned her teaching position to relocate.
- After separation, Gordon began work as a pediatrician at substantially higher income than Patricia, who experienced unemployment and later obtained lower-paying work at IBM.

## Issues

1. Whether the circuit court abused its discretion in dividing marital property without adequately accounting for Patricia’s financial and nonfinancial contributions to Gordon’s medical education and training.
2. Whether the circuit court abused its discretion by denying maintenance despite Patricia’s contributions and the parties’ markedly different future earning capacities.
3. How a court should reflect a spouse’s investment in the other spouse’s professional education and earning capacity when the degree itself is not divisible marital property.

## Decision

- The Wisconsin Supreme Court reversed the court of appeals.
- The Court held the circuit court abused its discretion in both the property division and the denial of maintenance.
- The Court vacated the portions of the divorce judgment addressing property division and maintenance.
- The case was remanded for further proceedings consistent with the Court’s directives.

## Legal Principles

- Property division and maintenance are discretionary decisions, but discretion is abused when the court fails to apply the correct legal standards or fails to reasonably account for the relevant statutory factors.
- A professional degree is not marital property subject to division; however, the economic consequences of one spouse’s support for the other’s education and training must be meaningfully reflected in the overall financial disposition.
- In an equitable dissolution, courts must give careful weight to a supporting spouse’s financial and nonfinancial contributions that enhanced the other spouse’s earning capacity.
- Property division and maintenance function together; courts may use either or both to achieve a fair aggregate result, especially where post-divorce earning capacities differ substantially.

## Conclusion

The Supreme Court required reconsideration of both property division and maintenance because the economic outcome did not fairly compensate the supporting spouse for years of financial and domestic contributions that enabled the other spouse’s professional training and significantly higher future earning capacity.


In re Marriage of Haugan v. Haugan, 117 Wis. 2d 200, 343 N.W.2d 796 (Wis. 1984)