## Facts

- Marguerite I. Nardini (wife) and Ralph E. Nardini (husband) married in 1953 and dissolved their marriage in 1985 after 31 years.
- The principal asset was a closely held group of related entities tied to a fire-protection-equipment business, including a Minnesota operating company, a North Dakota company, and a real-estate holding company.
- Ralph entered the fire-equipment business before the marriage, but the scope and value of his premarital interest at the time of marriage were disputed and weakly documented.
- During the marriage, the parties expanded and incorporated the enterprise, acquired remaining interests, and developed related entities; the parties jointly held all shares, with Ralph holding 60% and Marguerite 40%.
- Ralph served as president and received substantial compensation and perquisites; Marguerite contributed through supportive and household roles, including some business assistance.
- The district court valued the Minnesota corporation, treated one-half of its current value as Ralph’s nonmarital property, awarded Marguerite a share of marital property, and awarded temporary spousal maintenance of $1,200 per month for five years; it denied attorney’s fees.
- The court of appeals affirmed the valuation, the nonmarital characterization, and the temporary maintenance award.
- The Minnesota Supreme Court granted review.

## Issues

1. Whether the district court abused its discretion in valuing the closely held corporation that constituted the main marital asset.
2. Whether the district court erred by characterizing one-half of the business’s present value as the husband’s nonmarital property.
3. Whether the district court erred by awarding only temporary spousal maintenance in a long-term, traditional marriage.

## Decision

- The Supreme Court affirmed in part, reversed in part, and remanded.
- The district court abused its discretion in valuing the closely held corporation by failing to consider relevant facts and basic valuation elements; revaluation was required.
- The district court erred in treating one-half of the business’s current value as nonmarital; any nonmarital component had to be properly identified and traced rather than assumed.
- The court affirmed the equal (50/50) division of whatever portion of the business was determined to be marital.
- The district court erred in awarding only temporary maintenance; the wife was entitled to permanent spousal maintenance, with the amount to be set on remand.

## Legal Principles

- A dissolution valuation of a closely held business must be fair and reasonable and reflect the enterprise as a going concern, based on relevant facts and accepted valuation considerations.
- In valuing a marital business interest, a court must avoid methodologies that distort value by focusing narrowly on a fractional block of stock or applying discounts in a manner that misstates the value of the marital estate.
- Property acquired during marriage is presumed marital; a claimed nonmarital component must be proven and traced, and a large share of current value cannot be labeled nonmarital without evidentiary support tying it to premarital value.
- In a long-term, traditional marriage where one spouse has limited realistic prospects of achieving self-support at the marital standard of living, permanent spousal maintenance is appropriate; future changes are addressed through modification rather than automatic termination.

## Conclusion

The Minnesota Supreme Court required a new valuation of the closely held business, rejected an unsupported designation of half the business’s present value as nonmarital while confirming equal division of the marital portion, and held that the wife was entitled to permanent spousal maintenance, with the amount to be determined on remand.


Nardini v. Nardini, 414 N.W.2d 184 (Minn. 1987)