## Facts

- The parties were married slightly over two years, had no children, separated on January 2, 1984, and dissolution proceedings followed.
- Both spouses were employed throughout the marriage and after separation.
- The trial court ordered temporary spousal support of $500 per month for a defined period and then reserved jurisdiction over future spousal support.
- After separation, each spouse used separate earnings to pay preexisting community obligations, which the trial court found were made with a reasonable expectation of reimbursement and not as satisfaction of a support duty.
- The trial court limited reimbursement for these postseparation payments by applying Civil Code section 4800.2, restricting reimbursement to reductions of principal on the debts.
- The trial court treated a gun collection as community property, valued it, and awarded it to the husband; neither party requested a statement of decision.
- A restraining order prohibited disposal of the wife’s separate-property jewelry; the husband admitted throwing it into the sea, and the parties stipulated its value at $5,000.
- The trial court ordered reimbursement for the destroyed jewelry by offsetting $5,000 against the husband’s share of community property.
- The husband appealed the reservation of spousal-support jurisdiction, the limitation on reimbursement for postseparation payments, the gun-collection valuation, and the reimbursement order for the destroyed jewelry.

## Issues

1. Whether the trial court abused its discretion by retaining open-ended jurisdiction over spousal support after a short-duration marriage where temporary support was adequate and both parties were employed.
2. Whether Civil Code section 4800.2 limits reimbursement for postseparation separate-property payments on community obligations (Epstein-type reimbursement).
3. Whether the husband could challenge the trial court’s valuation of the community interest in the gun collection on appeal when no statement of decision was requested and substantial evidence supported the valuation.
4. Whether the dissolution court had jurisdiction to order reimbursement from the wrongdoer’s community-property share for willful destruction of the other spouse’s separate property.

## Decision

- The court reversed the order retaining open-ended jurisdiction over spousal support, holding it was an abuse of discretion as a matter of law in this short-duration marriage with adequate temporary support and employed spouses.
- The court reversed the limitation on reimbursement for postseparation payments, holding Civil Code section 4800.2 was inapplicable to Epstein-type reimbursements and did not restrict the trial court’s reimbursement discretion.
- The court affirmed the valuation and award of the gun collection, holding the failure to request a statement of decision was fatal to the valuation challenge where substantial evidence supported the result.
- The court affirmed the reimbursement/offset order for the destroyed jewelry, holding the dissolution court had jurisdiction to order reimbursement from the spouse’s community share for willful destruction of the other spouse’s separate property.
- The matter was remanded for further proceedings consistent with the reversals.

## Legal Principles

- For spousal support analysis, the “duration of the marriage” runs from the date of marriage to the date of separation; premarital cohabitation does not extend the marriage duration for support purposes.
- In a short-duration marriage with no children, adequate temporary support, and employed spouses, retaining open-ended spousal-support jurisdiction may constitute an abuse of discretion.
- Civil Code section 4800.2 addresses reimbursement for separate-property contributions to the acquisition of community property and does not limit equitable reimbursement for postseparation separate-property payments on community obligations under Epstein principles.
- An appellant who fails to request a statement of decision generally cannot obtain reversal of an asset valuation if substantial evidence could support the valuation; implied findings are presumed in favor of the judgment.
- A dissolution court has equitable authority to order reimbursement, via offset against a spouse’s community share, when that spouse willfully destroys the other spouse’s separate property.

## Conclusion

The appellate court limited postjudgment support authority in a short marriage, clarified that statutory reimbursement limits for acquisition contributions do not constrain Epstein reimbursements for postseparation debt payments, and upheld both a valuation supported by substantial evidence absent a statement of decision and an offset remedy for intentional destruction of separate property.


In re Marriage of Hebbring, 255 Cal. Rptr. 488 (Cal. Ct. App. 1989)