## Facts

- Karen Mae Shurtliff and Donald K. Shurtliff were married in 1959 and divorced after a 26-year marriage.
- Karen spent the marriage as a homemaker with limited formal education and little work history.
- Donald worked for the railroad and was the sole wage earner, earning over $54,000 annually.
- The trial court found Donald committed adultery and that he controlled the couple’s finances and impeded Karen’s attempts to work and pursue education.
- The divorce decree required Donald to pay all community debts, pay Karen spousal maintenance of $750 per month for five years, and pay $1,400 per year for five years toward Karen’s educational expenses.
- The trial court also awarded Karen attorney’s fees and costs.
- After the district court affirmed in an intermediate appellate proceeding, Donald appealed to the Idaho Supreme Court.

## Issues

1. Whether the trial court’s findings of fact were supported by substantial and competent evidence.
2. Whether the trial court abused its discretion by ordering a disparate division of the community estate, including assigning all community debts to Donald.
3. Whether the awards of time-limited spousal maintenance and educational expenses constituted an abuse of discretion.
4. Whether the award of attorney’s fees to Karen was a proper exercise of discretion.

## Decision

- The Idaho Supreme Court affirmed the district court’s affirmance of the divorce decree.
- The Court upheld the trial court’s findings of fact as supported by substantial and competent evidence, even if the evidence was conflicting.
- The Court upheld the disparate allocation of community debts and property as an equitable distribution within the trial court’s discretion.
- The Court upheld the rehabilitative maintenance and educational-expense awards as supported by Karen’s need and Donald’s ability to pay.
- The Court upheld the attorney’s-fee award as a discretionary decision justified by the parties’ relative financial positions and equities.

## Legal Principles

- Appellate courts will not disturb a trial court’s factual findings if supported by substantial and competent evidence; credibility and weight determinations are for the trial judge.
- In divorce actions, division of community property and debts is reviewed for abuse of discretion; a division may be unequal if equitable under the circumstances.
- Spousal maintenance may be awarded where a spouse lacks sufficient property to meet reasonable needs and cannot presently support themselves through employment; time-limited, rehabilitative awards may be appropriate to facilitate self-support through education or training.
- Attorney’s fees in domestic relations cases may be awarded based on need, ability to pay, and overall fairness; such awards are reviewed for abuse of discretion.

## Conclusion

The Idaho Supreme Court affirmed a divorce decree that imposed an unequal debt allocation, rehabilitative spousal maintenance, educational-expense support, and attorney’s fees, holding that the trial court’s findings were supported by substantial and competent evidence and that the financial awards were within the trial court’s discretion to reach an equitable result.


Shurtliff v. Shurtliff, 112 Idaho 1031, 739 P.2d 330 (Idaho 1987)