In Hall v. Hall,[1] the supreme court held that an ex-husband was not entitled to a Ramsey credit for his post-divorce mortgage payments because he had been living rent-free in the marital home; however, because the trial court did not sufficiently explain its ruling on that issue, a meaningful review of the order allocating the sale proceeds from the home was impossible. During their divorce, Bertha Hall moved out while Adolph Hall continued living rent-free in the marital home. Until the property sold two years later, Adolph paid the mortgage. The superior court denied reimbursement to Adolph for those mortgage payments, citing Bertha’s argument that any reimbursement would be in the form of a Ramsey credit and would therefore need to be offset by Adolph’s imputed rent. On appeal, the supreme court held that Ramsey applies to payments made to maintain marital property from post-divorce until the time of sale, and that the superior court was required to conduct a Ramsey analysis, complete with written findings explaining its decision. However, the supreme court vacated the superior court’s order and remanded, noting that the ruling below did not explain whether Adolph was denied a Ramsey credit or instead whether Ramsey was inapplicable in this case because the parties had divorced more than two years prior. The supreme court held that Adolph was not entitled to a Ramsey credit for his post-divorce mortgage payments because he had been living rent-free in the marital home; however, because the superior court did not sufficiently explain its ruling, the order allocating the sale proceeds from the home was vacated and remanded for additional written explanation.
[1] 446 F.3d 781 (Alaska 2019).
