Dawn Delozier v. Howard Delozier

Summary

The court held that permanently equalizing the parties’ net incomes was an abuse of discretion because the award was too speculative and insufficiently tied to the statutory maintenance criteria, despite the wife’s homemaking contributions and continuing childcare responsibilities. It remanded for an award providing rehabilitative support and compensation while encouraging economic independence, without precluding an appropriately justified permanent award. The court also held that a limited-period equalization formula and deferral of the child-tax-exemption issue could be used on remand if appropriate.