Kaven L. Rumpel v. Kathie W. Rumpel (now Wolford) and Diana L. Skaggs

Summary

The court held that the trial court improperly imposed attorney’s fees as a discovery sanction because the denied requests concerned genuinely disputed business values and Kaven had reasonable grounds to deny them. Although the record could support an attorney-fee award under the domestic-relations fee-shifting statute, the trial court had to make that determination in the first instance rather than relying on the discovery-sanction rationale. The court also held that the post-judgment valuation increase was improper because the issue and supporting evidence could have been presented before judgment, and it remanded for reconsideration of fees and reinstatement of the original property award.