The Appellate Group

Bonham v. Bonham

Bonham v. Bonham, 2026 UT App 141 (Orme, J.)

Family Law

The Utah Court of Appeals held:

(1) The district court improperly awarded equity in house to wife as a disclosure sanction against husband where husband complied with disclosure requirements.
(2) The district court improperly awarded 75% of dissipated assets to wife as a sanction against husband where court did not consider dissipation factors and where, in any event, a spouse is only entitled to half of dissipated assets.
(3) The district court did not abuse its discretion in valuing marital business where value was supported by evidence presented at trial.
(4) The district court did not adequately address alimony factors where court did not make express finding of payor’s reasonable monthly expenses.
(5) The district court correctly awarded initial attorney fees on equitable basis but failed to make detailed findings on reasonableness of said fees.
(6) The district court did not make adequate findings regarding factors relevant to post-trial attorney fees award.

Read the full court opinion