Stansberry v. Stansberry
1978 OK 77, 1978 Okla. LEXIS 401, 580 P.2d 147 (1978)
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Rule of Law:
When determining an alimony award in a divorce, a court must consider factors including the parties' station in life, the length of the marriage, the husband's earning capacity, and the wife's physical condition. An appellate court will not overturn such an award absent an abuse of the trial court's discretion.
Facts:
- Billie Jo Stansberry and Richard D. Stansberry were married in 1954 and the marriage lasted for approximately nineteen years.
- During the first ten years of the marriage, Billie Jo worked as a secretary, supporting Richard while he attended medical school and began his career.
- Richard became a successful doctor, and the family enjoyed a high standard of living, including a home in an affluent neighborhood, private schooling for their son, and frequent expensive vacations.
- Billie Jo developed progressive macular degeneration of the eyes, with a medical prognosis of eventual legal blindness, which made it increasingly difficult for her to work.
- At the time of the divorce proceedings, Richard's medical practice generated a gross income of approximately $140,000 per year.
- The parties had one son, who was 13 years old at the time of the trial.
Procedural Posture:
- The trial court entered a divorce decree for Billie Jo Stansberry (wife) and Richard D. Stansberry (husband).
- The trial court awarded the wife a division of property, alimony for support, child support, and attorney fees.
- Both parties appealed the trial court's judgment to the Court of Appeals (an intermediate appellate court).
- The Court of Appeals affirmed parts of the trial court's decision but reduced the child support award.
- The case was then appealed to the Supreme Court of Oklahoma for final review.
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Issue:
Did the trial court abuse its discretion in awarding significant alimony and child support by considering the parties' high standard of living, the husband's substantial earning capacity, the length of the marriage, and the wife's deteriorating physical condition?
Opinions:
Majority - Lavender, Vice Chief Justice
No, the trial court did not abuse its discretion. The determination of alimony is not limited to bare necessities but requires consideration of the parties' station in life, the husband's earning capacity, and the wife's physical condition. Citing Durland v. Durland, the court found that these factors fully justified the award. Given the long-term marriage, the high standard of living the parties enjoyed, the husband's significant income, and the wife's degenerative eye condition impairing her future earning ability, the trial court's alimony and child support awards were not an abuse of discretion. The standard of review on appeal is highly deferential and does not permit the appellate court to substitute its own judgment for that of the trial court.
Analysis:
This decision reinforces the principle that alimony is not merely for subsistence but can serve to maintain the marital standard of living for the recipient spouse, particularly after a long-term marriage. It solidifies that a spouse's significant earning capacity and the other's physical disability are critical factors in justifying a substantial support award. The case also underscores the high bar for overturning a trial court's alimony determination on appeal, cementing the 'abuse of discretion' standard, which grants trial judges considerable latitude in weighing the equitable factors of a divorce.
