Elizabeth M. v. Michael M.

Intermediate Court of Appeals of West Virginia·Decided August 6, 2026·No. 25-ICA-355·Unpublished

Opinion

IN THE INTERMEDIATE COURT OF APPEALS OF WEST VIRGINIA FILED August 6, 2026

ELIZABETH M.

ASHLEY N. DEEM, CHIEF DEPUTY CLERK Petitioner Below, Petitioner INTERMEDIATE COURT OF APPEALS OF WEST VIRGINIA

v.) No. 25-ICA-355 (Fam. Ct. Wayne Cnty. Case No. FC-50-2022-D-109)

MICHAEL M., Respondent Below, Respondent

MEMORANDUM DECISION

Petitioner Elizabeth M.1 (“Wife”) appeals the Family Court of Wayne County’s August 6, 2025, Amended Final Divorce Decree, which denied her request for spousal support. Respondent Michael M. (“Husband”) filed a summary response in support of the court’s order.2 Wife did not file a reply.

This Court has jurisdiction over this appeal pursuant to West Virginia Code § 51-

11-4 (2024). After considering the parties’ arguments, the record on appeal, and the applicable law, this Court finds no substantial question of law and no prejudicial error. For these reasons, a memorandum decision affirming the family court’s order is appropriate under Rule 21 of the West Virginia Rules of Appellate Procedure.

The parties were married in June of 1995 and had three children together, M.M., born November 1, 2005, and twins K.J.M. and K.E.M., born October 11, 2006. The couple last resided together on October 21, 2020.

Wife filed for divorce on April 20, 2022, alleging irreconcilable differences and seeking the marital home, child support, and spousal support. Her financial disclosure, also filed April 20, 2022, stated she had no income and had monthly expenses totaling $300 for gasoline and food. Husband filed his answer, counterpetition for divorce, and financial disclosure on May 4, 2022. He also alleged irreconcilable differences and a voluntary separation of the parties but alleged that Wife was guilty of cruel and inhuman treatment toward him and had committed adultery. His financial statement did not include a specific

1 To protect the confidentiality of the juveniles involved in this case, we refer to the parties’ last name by the first initial. See, e.g., W. Va. R. App. P. 40(e); State v. Edward Charles L., 183 W. Va. 641, 645 n.1, 398 S.E.2d 123, 127 n.1 (1990).

2 Wife is represented by Jon D. Hoover, Esq. Husband is represented by Juston H.

Moore, Esq.

figure for his income and stated only that it varied. Husband also stated that Wife is able to work and has a work history, and that she left the marriage for another man.

The record reflects that Wife requested temporary spousal support at a February 15, 2023, hearing, which the family court denied after finding, in part, that it lacked enough information to grant the request. Specifically, the court found it could not analyze Wife’s need or Husband’s ability to pay.

At the next hearing on September 26, 2023, Wife’s counsel introduced an exhibit detailing Wife’s estimated monthly expenses if she had the financial resources to live independently. However, the expenses were only estimates because Wife had no income and was not paying rent, utilities, or any other bills after leaving the marital home. Husband continued to pay for Wife’s cellphone and car insurance, and she was reliant on others for her needs. Husband paid all the joint marital expenses, was the sole provider for the parties’ children, and sought to waive his right to receive child support from Wife.3 Accordingly, Husband argued he could not afford to pay spousal support.

In an October 3, 2023, letter to counsel, the family court again denied requests for temporary spousal support. In the letter, the family court stated,

[Wife] clearly has a need, but rather than pay her temporary spousal support and then have her pay child support, her phone, and half (½) of the marital debts from the award, it makes more sense on a temporary basis to order [Husband] be responsible for the marital debts, pay [Wife’s] cell phone, and waive temporary child support.4 The [c]ourt also continues to find it persuasive that [Husband] is solely financially responsible for meeting the parties’ three (3) minor children’s need – which, now includes orthodontic braces. It would not be appropriate at this time, to risk [Husband] not being able to meet the children’s financial needs when that burden falls solely to him, simply to provide [Wife] temporary spousal support.

3 The Supreme Court of Appeals of West Virginia has made clear that “[t]he duty of a parent to support a child is a basic duty owed by the parent to the child, and a parent cannot waive or contract away the child’s right to support.” Syl., Rebecca C. v. Michael B., 213 W. Va. 744, 584 S.E.2d 600 (2003); see also Syl. Pt. 3, Wyatt v. Wyatt, 185 W. Va. 472, 408 S.E.2d 51 (1991).

4 We note that despite Father’s attempts to waive child support, the family court did not allow Father to do so. Instead, the family court set Mother’s monthly child support obligation at $0, which is reflected in the final order on appeal.

The letter also mentioned that during the February 15, 2023, hearing, Wife’s argument for temporary spousal support was couched in terms of being necessary to help her until she found a job. However, the family court observed that Wife,

has yet to put any real effort into finding employment to help herself financially. Counsel . . . even acknowledged in February that [Wife] has a duty to get back on her feet but asked for assistance until presumabl[y] she was able to get back on her feet. Yet, at this most recent hearing, it was clear that she is unwilling to seek any type of employment.

The family court proceeded to a final hearing conducted February 22, 2024, and July 30, 2024, where it took testimony, evidence, and argument regarding the parties’ assets, expenses, and child/spousal support. The court heard significant testimony and argument regarding Husband’s income, which had not been produced in the initial financial disclosures because of his sporadic workload and variable income. During the February 22, 2024, hearing, the parties reviewed Husband’s most recent pay stub, and the court attempted to extrapolate his yearly earnings. Husband testified regarding his monthly expenses and the costs associated with being the sole caretaker and provider for their three children. Husband argued that any expendable income he had was invested in the children’s needs and he had nothing left over to pay towards spousal support.

During the proceedings, both parties asked to be awarded the marital home, which would require a significant equalization payment to the other party. Husband argued that Wife could not obtain financing or afford to buy him out because she was unemployed. Wife rebutted that she would “beg, borrow, and steal” to find the money to keep the marital home. Simultaneously, Wife renewed her request for spousal support and provided an updated and revised estimate of monthly expenses if she lived independently. Husband again objected to Wife’s speculative financial need.

Wife was questioned at length about her lack of effort in seeking employment. Wife asserted that she was a stay-at-home mother for most of the marriage, had been out of the labor market for more than twenty years, and was not able to find work. She testified that she had only applied for one job since the parties separated in 2020. She alleged she went to a nearby convenience store and briefly trained for a cashier position but was sent home and told to try again after she had more experience. Husband’s counsel countered that even high school students with no experience could find a job at a fast-food restaurant and make more than minimum wage. Furthermore, Wife’s life experience as a stay-at-home parent gave her transferable skills in childcare and domestic tasks that qualified her for entry level work in janitorial services, food preparation, or similar employment, even as a means of defraying her cost of living.

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Elizabeth M. v. Michael M., (W. Va. Ct. App. 2026).

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