Rainwater v. Rainwater
177 Ariz. 500, 869 P.2d 176, 142 Ariz. Adv. Rep. 15 (1993)
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Rule of Law:
A court does not abuse its discretion by awarding indefinite spousal maintenance if it is unlikely the receiving spouse can become self-supporting at a level reasonably approximate to the standard of living established during the marriage. This is especially true in long-term marriages where the receiving spouse contributed significantly to the paying spouse's earning ability.
Facts:
- Sam Rainwater and Barbara Rainwater were married for twenty-two years.
- Early in the marriage, Barbara Rainwater worked full-time to help support Sam Rainwater while he earned an engineering degree.
- Throughout the marriage, Barbara Rainwater maintained the home and was the primary caretaker for the couple's two children.
- Barbara Rainwater also contributed socially and emotionally to Sam Rainwater's professional career after he completed his degree.
- As a result of his engineering career, Sam Rainwater's annual income rose substantially, exceeding $100,000 in the years just prior to the divorce.
- At the time of the dissolution, Barbara Rainwater was forty-one years old, worked as a secretary, and was pursuing a Bachelor of Arts degree.
- The parties had achieved a relatively high standard of living by the last years of their marriage.
Procedural Posture:
- Barbara Rainwater ('wife') petitioned the superior court to dissolve her marriage to Sam Rainwater ('husband').
- The parties resolved all issues by stipulation except for spousal maintenance for the wife.
- The superior court, acting as the trial court, held a trial on the single issue of spousal maintenance.
- The trial court awarded wife spousal maintenance until her death or remarriage, with a higher amount for the first three years.
- Sam Rainwater, as appellant, appealed the trial court's order to the Arizona Court of Appeals.
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Issue:
Does a trial court abuse its discretion by awarding indefinite spousal maintenance to a spouse who is able to work, when that spouse's earning capacity is insufficient to maintain the standard of living established during the marriage?
Opinions:
Majority - Fidel, Chief Judge.
No, the trial court did not abuse its discretion. An award of indefinite spousal maintenance is permissible when statutory factors, particularly the marital standard of living and the receiving spouse's contributions to the paying spouse's earning capacity, indicate that the receiving spouse cannot realistically become self-supporting at a level approximating the marital lifestyle. The court reasoned that the public policy goal of financial independence must be balanced with a realistic appraisal of the receiving spouse's future earning potential relative to the standard of living achieved through the couple's common efforts over a long marriage. Here, after a 22-year marriage where the wife supported the husband's education and career, it was unlikely she could ever independently achieve their high standard of living. The court also noted that an indefinite award is not immutable; it is modifiable and simply places the burden on the paying spouse to later prove a substantial change in circumstances warrants its termination or reduction.
Analysis:
This decision clarifies that spousal maintenance in Arizona is not merely a short-term, rehabilitative tool to ensure basic self-sufficiency. It reinforces the principle that maintenance can serve an equitable function, compensating a spouse for contributions to the other's career and for a reduced earning capacity resulting from marital roles. The case solidifies the 'standard of living' as a key benchmark for determining not just the amount, but also the duration of a maintenance award, making it harder for high-earning spouses to terminate support obligations solely because the recipient spouse is able-bodied and employed at a lower income level.
