## Facts

- Ann K. Huntington (wife) and John B. Huntington (husband) married August 24, 1985, and separated March 28, 1989, after about three years and seven months.
- Before marriage, wife (age 28) worked as a dental hygienist earning about $30,000 annually; she stopped working shortly before marriage after husband told her she need not work.
- Husband (age 47) had a net worth exceeding $15 million, owned high-value real property, and had substantial investment cash flow; the marital standard of living was found “extremely high.”
- The parties signed a premarital agreement the day before marriage providing that each party’s property would remain separate.
- Husband filed for legal separation in March 1989 and later sought dissolution; wife received temporary spousal support of $7,500 per month starting May 1, 1989.
- Husband paid $19,000 toward wife’s attorney’s fees under a prior order and stipulation.
- After trial in October 1990, the court ordered spousal support of $5,000 per month for six months, terminating permanently thereafter, and ordered each party to bear their own attorney’s fees and costs.
- The trial court granted reconsideration on fees but reaffirmed its denial of additional attorney’s fees.
- Wife appealed, challenging the lack of a written statement of decision, the amount and duration of spousal support, and the denial of additional attorney’s fees.

## Issues

1. Whether the judgment required reversal because the trial court did not issue a written statement of decision after an asserted request under Code of Civil Procedure section 632.
2. Whether the trial court misinterpreted and misapplied former Civil Code section 4801 and abused its discretion by ordering $5,000 per month for six months with permanent termination thereafter.
3. Whether the trial court abused its discretion by denying wife additional attorney’s fees and costs beyond the $19,000 previously paid.

## Decision

- The Court of Appeal affirmed the judgment and related orders.
- The absence of a written statement of decision did not warrant reversal because wife failed to show prejudice.
- The spousal support award was upheld; the trial court applied the correct legal framework and did not abuse its discretion in limiting the amount and duration.
- The denial of additional attorney’s fees and costs was upheld as within the trial court’s discretion.

## Legal Principles

- Failure to issue a statement of decision is not reversible per se; the appellant must show prejudice, such as impaired appellate review or masked error.
- Under former Civil Code section 4801, spousal support requires consideration of multiple statutory factors, including marital standard of living, duration of marriage, needs, ability to pay, and the supported spouse’s earning capacity; no single factor is controlling.
- Trial courts have broad discretion in setting spousal support, and appellate courts review for abuse of discretion, not to reweigh statutory factors.
- In a relatively short marriage, a court may order limited-duration support when the supported spouse is employable and transitional support is reasonable, even if the marital standard of living was very high and the supporting spouse is extremely wealthy.
- Attorney’s fee awards in dissolution proceedings are discretionary and turn on need and ability to pay; denial of additional fees is proper absent a showing that the ruling prevented meaningful access to counsel or fair litigation.

## Conclusion

The Court of Appeal affirmed limited, time-bound spousal support and denial of additional attorney’s fees after a short marriage, holding that the trial court reasonably weighed the statutory factors and that reversal was not required for lack of a written statement of decision without a showing of prejudice.


In re Marriage of Huntington, 10 Cal. App. 4th 1513, 14 Cal. Rptr. 2d 1 (Cal. Ct. App. 1992)