## Facts

- Matthew Roberts (husband) and Leigh Anne Roberts (wife) married in June 1989.
- At the time of marriage, husband worked for a bank.
- In 1990, the parties agreed husband would attend law school full-time while wife would support the household financially and handle the home’s day-to-day responsibilities.
- Husband incurred student loan debt during the marriage to finance law school.
- The parties separated about two months before husband’s graduation from law school.
- At separation, wife was pregnant.
- After graduation, husband obtained employment with a large law firm in Chicago.
- Husband filed a petition for dissolution in August 1993.
- The trial court concluded husband’s law degree was not a marital asset subject to distribution.
- The trial court treated the student loans as a marital liability and assigned husband full responsibility for repayment.
- After allocating the parties’ assets and liabilities, the trial court’s distribution left husband with a net liability of $2,415.04 and wife with net assets of $25,534.98.
- Wife appealed the property and debt allocation, challenging the treatment of the law degree and the allocation of the educational debt.

## Issues

1. Whether the trial court erred or abused its discretion in dividing the marital estate by ruling that the husband’s law degree was not marital property while treating the student loan debt as a marital liability and allocating that debt to husband.

## Decision

- The Indiana Court of Appeals affirmed the trial court’s dissolution decree.
- The court agreed that a professional degree (standing alone) is not marital property subject to division.
- The court upheld treating student loan debt incurred during the marriage as part of the marital estate for allocation.
- The court held the trial court acted within its discretion in assigning the educational debt to husband and in the overall division of assets and liabilities.

## Legal Principles

- A professional degree or educational credential obtained during marriage is generally not “property” subject to division in a dissolution decree.
- Debts incurred during the marriage, including educational loans, may be included in the marital estate and allocated between spouses as part of the property division.
- Indiana dissolution courts start from a presumption that an equal division is just and reasonable, but that presumption may be rebutted based on statutory considerations such as each spouse’s contributions and economic circumstances.
- A trial court has broad discretion to allocate specific debts to one spouse, so long as the overall division is just and reasonable; appellate review focuses on whether the division is clearly against the logic and effect of the facts and reasonable inferences.

## Conclusion

The Court of Appeals affirmed the dissolution order, holding that the trial court properly refused to treat the husband’s law degree as marital property and acted within its discretion in treating the student loans as marital debt and assigning repayment responsibility to husband as part of an overall division the court found just and reasonable.


In re Marriage of Roberts, 670 N.E.2d 72 (1996)