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Appellate Division upheld equitable distribution awarding defendant one-third value of marital jewelry business. Kamm v. Kamm, 120 N.Y.S.3d 815 (N.Y. App. Div. 2020)

The equitable distribution of marital property and the award of maintenance are central issues in many divorce cases. A case from the Supreme Court, Nassau County, involving a long-term marriage and disputes over the division of a jewelry business and the awarding of maintenance, provides a clear illustration of these issues.

Background Facts
The plaintiff and defendant were married in 1984 and had two children who were emancipated by the time of the trial. Early in the marriage, the plaintiff sold the parties’ townhouse and the defendant’s engagement ring to open a jewelry business. This business became the family’s primary source of income. The defendant left her job as a credit investigator to focus on homemaking and raising the children.

In 1999, the couple separated but agreed that the plaintiff would provide financial support while the defendant lived with and cared for the children. This arrangement continued for approximately ten years. In 2011, the plaintiff initiated a divorce action seeking ancillary relief.

During the nonjury trial, the court addressed issues related to the equitable distribution of marital assets, including the jewelry business, and the defendant’s request for spousal maintenance. The trial court’s judgment, entered in December 2016, awarded the defendant $170,000, representing one-third of the value of the jewelry business, and spousal maintenance of $3,500 per month until 2019, decreasing to $3,000 per month until 2022. The plaintiff appealed these determinations.

Question Before the Court
The appellate court was tasked with reviewing whether the trial court properly:

  1. Distributed the jewelry business as marital property, awarding the defendant one-third of its value.
  2. Determined the amount and duration of spousal maintenance awarded to the defendant.

Court’s Decision
The appellate court affirmed the trial court’s judgment. It concluded that:

  1. The defendant’s one-third interest in the jewelry business was appropriate, as the business was funded with both the defendant’s personal property (her engagement ring) and joint marital property (the townhouse). The defendant’s role as a homemaker and caregiver also supported her entitlement to a share in the business.
  2. The spousal maintenance award was reasonable given the duration of the marriage, the defendant’s prolonged absence from the workforce, and her limited earning potential. The court found that the plaintiff had a higher income than reported and that the maintenance amount reflected the defendant’s needs and the plaintiff’s ability to pay.

Discussion

Equitable Distribution of the Jewelry Business. New York law treats marriage as an economic partnership, and marital assets are divided equitably, not necessarily equally. The jewelry business, created using both parties’ contributions, was considered marital property. The plaintiff used proceeds from the sale of the townhouse and the defendant’s engagement ring to start the business, and the defendant’s indirect contributions as a homemaker supported the family while the plaintiff operated the business. The court awarded the defendant one-third of the business’s value, reflecting her significant contributions.

The appellate court upheld this determination, emphasizing that equitable distribution accounts for both financial and non-financial contributions to a marriage. The court gave weight to the trial court’s credibility assessments, which found the plaintiff’s testimony about the business’s value and finances unreliable.

Spousal Maintenance Award. The court considered several statutory factors in determining the amount and duration of maintenance, including the marriage’s length, the standard of living during the marriage, the defendant’s earning capacity, and her absence from the workforce. The plaintiff’s income was imputed at a higher level than his reported earnings due to inconsistencies in his financial disclosures.

The maintenance award was structured to provide support during the defendant’s transition to financial independence while accounting for her limited prospects for self-sufficiency. The initial amount of $3,500 per month was reduced after three years to reflect the plaintiff’s obligation to assist the defendant during a defined period.

The appellate court found no error in the trial court’s assessment and concluded that the maintenance award balanced the parties’ needs and resources.

Conclusion
The appellate court’s decision in this case reinforces key principles in divorce proceedings involving long-term marriages. The equitable distribution of marital assets considers both direct and indirect contributions, and maintenance awards are tailored to support the less affluent spouse while promoting eventual independence.

If you are facing a divorce involving complex financial issues, it is essential to have an experienced attorney to guide you through the process and advocate for your rights. Contact the knowledgeable divorce lawyers at Stephen Bilkis & Associates to schedule a consultation. We are here to help you understand your options and achieve a fair resolution.

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