Background
Amanda and Travis Feeler divorced after a 23-year marriage that produced eight children. Amanda was the primary caregiver and homeschooled the children, while Travis was the principal wage earner through his elevator-company job. At trial, six children remained minors, including a five-year-old with developmental delays requiring therapy.
The district court gave Amanda physical care, ordered Travis to pay child support, imputed $62,400 in annual income to Amanda based on her construction and house-flipping skills, and awarded her $1,000 monthly in transitional spousal support for three years. It also ordered her to repay $46,000 she withdrew from the children’s savings accounts. Amanda appealed the decree’s economic provisions.
The Court’s Holding
The Iowa Court of Appeals upheld the income imputation and child-support calculation. The record supported the finding that Amanda could earn $30 per hour in construction or a related field, and Travis’s per diem payments were not income absent evidence that they exceeded his work-related travel expenses. The court declined to consider Travis’s request to recalculate his own income because he did not cross-appeal.
The court also upheld the order requiring Amanda to restore the $46,000 taken from the children’s accounts and found her undeveloped challenge to the property division inadequate for review. But it modified the spousal-support award: $1,000 per month was reasonable, yet a three-year transitional award was not equitable after this long-term marriage and given Amanda’s caregiving role. Travis must instead pay traditional spousal support until his retirement or death, or until Amanda remarries, cohabits with a new partner, or dies, whichever occurs first.
Key Takeaways
- A court may impute income when the evidence supports a parent’s earning capacity and actual income is not reliably established.
- Employer per diem is not treated as income without evidence it exceeded the employee’s travel expenses.
- A long marriage involving a stay-at-home primary caregiver can warrant traditional spousal support rather than short-term transitional support.
Why It Matters
The decision reinforces that the label attached to spousal support must fit its purpose. Transitional support generally addresses short-term liquidity needs, while long-term caregiving patterns and a marriage exceeding two decades may justify traditional support.
It also underscores that funds belonging to children are not marital property available for a parent’s use in maintaining marital assets.