Marriage of Sunderland

Colorado Court of Appeals·Decided August 27, 2026·No. 25CA0756·Unpublished

Opinion

25CA0756 Marriage of Sunderland 08-27-2026 COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0756 Jefferson County District Court No. 22DR30340 Honorable Christopher B. Rhamey, Judge

In re the Marriage of Sandra J. Sunderland, Appellant, and Stuart L. Sunderland, Appellee.

ORDER AFFIRMED

Division VII

Opinion by JUDGE SULLIVAN Pawar and Meirink, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)

Announced August 27, 2026

Sandra J. Sunderland, Pro Se

Ciancio Ciancio Brown P.C., Marc J. Kaplan, Banafsheh Lari, Denver, Colorado, for Appellee

¶1 In this post-decree dissolution of marriage case between Sandra J. Sunderland (wife) and Stuart L. Sunderland (husband), wife appeals the district court’s order denying her motion to modify maintenance and request for attorney fees. We affirm.

I. Relevant Facts and Procedural History ¶2 In 2023, the district court dissolved the parties’ twenty-seven- year marriage. At that time, husband was the fire chief for a local fire department, and he planned to retire in July 2024 (about eight months after the divorce). Wife was unemployed. ¶3 When dividing the marital estate, the court found that the marital home was worth $850,000. It acknowledged that wife wanted to keep the home, but the court found that it “couldn’t do [so] in a way that would be financially feasible.” The court directed the parties to sell the home. It allocated the home’s equity by giving wife the first $225,000, which encompassed $100,000 for an equalization payment and $125,000 for a reimbursement of husband’s marital waste during the case, and equally dividing the rest. (Given the court’s valuation, this gave wife $537,500 and husband $312,500.)

¶4 The court also equally divided the marital portion of husband’s pension but noted that it was unable to determine an exact amount each party would receive until husband’s upcoming retirement was finalized. The court awarded wife an IRA, which was worth about $145,000, and awarded husband other various retirement accounts, which totaled about $342,000. ¶5 The court ordered husband to pay wife maintenance in the amount of $3,585 per month until husband retired. It then reserved jurisdiction over maintenance, finding that the anticipated but unknown changes to the parties’ incomes after husband’s retirement could be significant. ¶6 After permanent orders, wife purchased husband’s interest in the marital home for $189,750 and continued to live in the home. ¶7 In July 2024, husband retired, and wife filed a motion to modify maintenance. She asked the court to extend husband’s maintenance obligation and requested $1,840 per month. ¶8 After a hearing, the court denied wife’s motion and terminated maintenance. The court found that wife was working part-time as a cashier and earned $21 per hour. It explained that it had provided wife with an equitable distribution of marital assets in the

permanent orders, including significant liquid assets from the sale of the marital home. Wife then elected to modify the court’s allocation by purchasing husband’s interest in the home. The court found that, after her purchase, wife’s total equity in the home increased to $660,250, which included the $225,000 the court awarded as her equalization payment and the reimbursement for husband’s marital waste. The court also found that she had inherited $100,000 after the divorce and noted that she was receiving $5,579 per month from husband’s pension. ¶9 The court then determined that husband’s seasonal job at a fly shop in Montana earning $13.50 per hour was reasonable, rejecting wife’s argument that he was voluntarily underemployed. It noted that husband’s main asset was his pension and that he received $9,078 per month from it — about $3,500 per month more than wife due to his premarital contributions. ¶ 10 The court found that wife chose to purchase the marital home and that wife’s equity in the marital home was significantly more than the difference in the monthly value of the pension. It then determined that wife had sufficient financial means to support herself and that her decision to retain the marital home equity

didn’t justify awarding her additional maintenance. The court also denied wife’s request for attorney fees under section 14-10-119, C.R.S. 2025.

II. Maintenance

¶ 11 Wife contends that the district court reversibly erred by denying her request to modify maintenance. We consider and reject her contentions.

A. Standard of Review ¶ 12 The district court has broad discretion when deciding maintenance, and, absent an abuse of that discretion, we will not disturb its decision. See § 14-10-114(2), (3)(e), C.R.S. 2025; In re Marriage of Vittetoe, 2016 COA 71, ¶ 14. A court abuses its discretion when it acts in a manifestly arbitrary, unreasonable, or unfair manner, or when it misapplies the law. In re Marriage of Young, 2021 COA 96, ¶ 7. We defer to the court’s factual findings unless they have no record support. In re Marriage of Capparelli, 2024 COA 103M, ¶¶ 30-31. We review de novo the court’s application of the law. In re Marriage of Tooker, 2019 COA 83, ¶ 12. ¶ 13 Generally, a request to modify maintenance is governed by section 14-10-122(1)(a), C.R.S. 2025, and requires a party to show

that substantial and continuing changed circumstances have rendered the maintenance award unfair. In re Marriage of Thorstad, 2019 COA 13, ¶¶ 1-2, superseded by statute on other grounds, Ch. 176, sec. 1, § 14-10-114(5), 2013 Colo. Sess. Laws 648, as stated in Young, ¶ 13. The court, however, may reserve jurisdiction at the time of the permanent orders based on a specific future event, and, when reserved, the court may modify maintenance under section 14-10-114 as though initially determining maintenance. See § 14-10-114(3)(g); Thorstad, ¶¶ 48-49; In re Marriage of Caufman, 829 P.2d 501, 503-04 (Colo. App. 1992). ¶ 14 Under section 14-10-114, the court must first make findings on each party’s gross income, the marital property apportioned to each party, each party’s financial resources, the reasonable financial need as established during the marriage, and the taxability of the maintenance awarded. § 14-10-114(3)(a)(I); In re Marriage of Wright, 2020 COA 11, ¶ 14. The court then considers the amount and term of maintenance, if any, that is fair and equitable based on the totality of circumstances. § 14-10-114(3)(a)(II), (3)(b), (3)(c), (3)(e); Wright, ¶ 15. The court may award maintenance only if it finds that the party seeking

maintenance lacks sufficient property to provide for their reasonable needs and is unable to support themselves through appropriate employment. § 14-10-114(3)(a)(II)(C), (3)(d); Wright, ¶ 16.

B. Pension Payments

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