In Re the Marriage of Kendrik Jon De Koning, Petitioner, and Melissa Christie De Koning, Respondent

Summary

The court held that, when attorney's fees are determined after entry of a dissolution decree, the trial court must assess the parties' financial resources as of the decree date or, if earlier, the date of the property-disposition hearing. The court rejected consideration of financial changes occurring before the later fee hearing because property division is the foundational financial determination and attorney's fees must be evaluated in relation to it. The court therefore reversed the court of appeals and remanded with instructions to reinstate the protective order and the trial court's order that each party pay his or her own fees.