## Facts

- Emmanuel J. Otis (husband) and Georgia Contos Otis (wife) married on June 6, 1954, and had one child.
- Wife was a skilled executive secretary at marriage, left the workforce to raise the child, and remained out of the labor market for many years.
- Husband became a highly compensated corporate executive, earning a salary exceeding $120,000 plus bonuses.
- The dissolution decree divided a substantial marital estate, awarding wife assets valued at about $225,704.50 and husband assets valued at about $210,620.50, plus husband’s vested pension interest and inherited property in Greece valued at about $85,000.
- The trial court found wife was in good health and, with additional training, could earn $12,000–$18,000 per year.
- The decree awarded maintenance to wife of $2,000/month (Dec. 1978–Dec. 1980), then $1,000/month (Jan. 1981–Dec. 1982), with termination thereafter.
- Wife appealed only the termination of maintenance after four years; the appeal was submitted without a transcript.

## Issues

1. Whether the trial court abused its discretion under Minn. Stat. § 518.552 by ordering maintenance for a limited four-year term rather than permanent maintenance.

## Decision

- The Supreme Court of Minnesota affirmed the decree.
- The court held the limited, decreasing maintenance award and its termination after four years fell within the trial court’s discretion.
- Because the appeal proceeded without a transcript, the court accepted the trial court’s factual finding that wife could become self-supporting with additional training.

## Legal Principles

- Maintenance awards under Minn. Stat. § 518.552 are reviewed for abuse of discretion; appellate courts defer to trial-court findings absent a record showing clear error.
- A court may award maintenance only upon statutory showings of need and inability to provide adequate self-support, and must consider factors including property received, earning capacity, time for education or training, marital standard of living, marriage duration, and the obligor’s ability to pay.
- Time-limited, rehabilitative maintenance is permissible where the recipient spouse is healthy, has transferable skills, and can reasonably be expected to reenter the labor market.
- When an appeal is submitted without a transcript, the appellant’s ability to challenge factual findings supporting maintenance duration is substantially limited.

## Conclusion

The court upheld a four-year, step-down maintenance award as a proper rehabilitative order under Minn. Stat. § 518.552, concluding that the trial court reasonably relied on wife’s health, employment potential with training, and significant property award, and did not abuse its discretion by terminating maintenance after the rehabilitative period.


Otis v. Otis, 299 N.W.2d 114 (Minn. 1980)