Killen v. Alben

CourtSupreme Court of Delaware
DecidedSeptember 7, 2023
Docket471, 2022
StatusPublished

This text of Killen v. Alben (Killen v. Alben) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Killen v. Alben, (Del. 2023).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

MICHAEL KILLEN, § § No. 471, 2022 Respondent Below, § Appellant, § Court Below: Family Court § of the State of Delaware v. § § File No. CN22-01660 CANDICE ALBEN, § § Petition No. 22-04577 Petitioner Below, § Appellee. §

Submitted: July 12, 2023 Decided: September 7, 2023

Before VALIHURA, TRAYNOR, and LEGROW, Justices.

Upon appeal from the Family Court of the State of Delaware. AFFIRMED IN PART, REVERSED IN PART, AND REMANDED.

Curtis P. Bounds, Esquire, Kara M. Swasey, Esquire, Megan McGovern, Esquire, BAYARD, P.A., Wilmington, Delaware, for Respondent Below, Appellant Michael Killen.

Jennifer A. Hartnett, Esquire, HARTNETT & HARTNETT, Hockessin, Delaware, for Petitioner Below, Appellee Candice Alben.

LEGROW, Justice: Michael Killen1 appeals from a Family Court order awarding alimony to his

ex-wife, Candice Alben, and directing Killen to maintain a pre-existing life

insurance policy during the alimony period with Alben as the sole beneficiary.

Killen challenges aspects of both rulings on appeal.

With respect to the alimony award, Killen argues on appeal that the Family

Court designated the incorrect date for his payment obligations to begin. The parties

continued to reside in the marital residence after their divorce and through the date

of trial. Before the matter was submitted, the parties agreed to sell the home and to

divide the proceeds at the court’s direction. The court’s order directed the parties to

continue to split household expenses while they resided together and required Killen

to begin making alimony payments upon the residence’s sale. Killen argues that his

alimony obligations instead should commence on the divorce date.

With respect to the insurance policy, Killen argues that the Family Court

directed the policy’s continued maintenance based on an inadequate record. Alben

did not seek any relief concerning the policy at trial. Instead, the Family Court

ordered the policy’s maintenance sua sponte. According to Killen, the Family Court

did not have sufficient evidence to order such relief and therefore abused its

discretion.

1 The Court previously assigned pseudonyms to the parties under Supreme Court Rule 7(d). For the reasons that follow, we affirm in part, reverse in part, and remand this

matter to the Family Court. Designating the date on which a party’s alimony

obligations begin is within the Family Court’s discretion, and we conclude the court

did not abuse its discretion in this case. On the other hand, the Family Court did not

have a sufficient factual record to order Killen to maintain the policy with Alben as

the sole beneficiary. On remand, the Family Court may accept any additional

evidence or submissions that it deems necessary to determine its authority, if any, to

direct the policy’s continued maintenance.

I. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND

On June 6, 2022, the Family Court entered a divorce decree ending the parties’

marriage of 14 years and 9 months.2 Candice Alben (“Wife”) is a grant analyst at

the University of Delaware, earning $56,000 annually.3 Michael Killen (“Husband”)

earns $118,000 annually working for Xerox.4 The parties moved to Delaware from

New York City in 20145 and share two children.6

Throughout the marriage, the parties divided responsibility for household

expenses under a longstanding arrangement: Husband paid the mortgage, while

Wife paid “other bills” concerning the home.7 Wife testified at trial that she always

2 Am. Opening Br. Ex. A (“Ancillary Order”) at 3, 17. 3 Am. App. to Opening Br. at A18, A50. 4 Id. at A77–78, A86–87. 5 Id. at A35. 6 Id. at A14, A18. 7 Id. at A35. 2 fulfilled her end of this marital bargain, even during a period of unemployment after

she left her job in New York City to relocate to Delaware.8 Wife also testified that

Husband took sole responsibility for the mortgage but ultimately fell behind on

monthly payments, resulting in a foreclosure notice being posted to the door of the

marital residence around 2018.9 According to Wife, when she asked Husband about

the notice, Husband told her not to worry about it because “the mortgage is not

[Wife’s] business.”10

The parties separated on August 22, 2019, but continued to reside in the

marital residence, along with their children, through the date of trial.11 For the first

few years after the parties’ separation, Wife resided in the master bedroom, while

Husband resided in the shared living space.12 But shortly after Wife filed her divorce

petition, Husband removed Wife’s belongings to the “back room” of the home.13

From that point on, Wife shared a bedroom with the parties’ daughter, and Husband

resided in the master bedroom while purporting to limit Wife’s access to the

residence by placing signs on various doors throughout the home.14

8 Id. at A35–36. 9 Id. at A33–34. 10 Id. at A34. 11 Id. at A14–15. The record on appeal does not indicate whether the parties have since moved out of the marital residence. 12 Id. at A15–17. 13 Id. at A16–17. Wife filed her divorce petition on February 16, 2022. Ancillary Order at 2. 14 Am. App. to Opening Br. at A16–17, A32–33. 3 Trial on matters ancillary to the parties’ divorce occurred on

November 7, 2022.15 Before the case was submitted, the parties agreed to list the

marital residence for sale and to divide the sale proceeds at the Family Court’s

direction.16 Trial was relatively inefficient. Husband was self-represented and,

perhaps as a result, failed to provide the court with key information.17 The gaps in

Husband’s evidence required the trial court to go to “great lengths to ‘mine’

information that Husband should have been prepared to present.” 18

The court issued its Order on Matters Ancillary to Divorce (the “Ancillary

Order”) not long after trial. Several aspects of the Ancillary Order are relevant to

this appeal. First, the court found that Husband earned 67% of the parties’ combined

income.19 The court ordered the proceeds from the sale of the marital home to be

used to satisfy certain marital debts, with the balance to be divided by a 65–35 split

between Wife and Husband.20 Because the sale would inevitably take time, the court

ordered each party to contribute to the mortgage payment and household expenses,

15 Ancillary Order at 3. 16 Id. at 10. 17 For example, Husband sought credits for certain expenses that he claimed he incurred during the marriage, but he provided no supporting documentation and failed to include within those expenses his monthly payments on the life insurance policy. Id. at 8–9, 21. He also failed to provide documentation showing the amount in his 401(k) account that accrued before the parties’ marriage. Id. at 13–14. The court ultimately gave Husband credit for his monthly payments on the life insurance policy. See id. at 27. 18 Id. at 2. 19 Id. at 20. 20 Id. at 21. 4 with Husband paying two-thirds of those expenses and Wife paying for the

remaining one-third.21 The court’s division of these expenses accorded with the

portion of the household income each spouse earned.22

Second, the Family Court found Wife financially dependent and awarded her

monthly alimony of $1,300 for 84 months.23 Acknowledging that the parties “will

undergo significant financial changes as they implement th[e] [A]ncillary [O]rder,”

the court ordered Husband’s alimony obligations to begin upon the sale of the

marital residence.24

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